CLP Notification is now required under EU law for any substance placed on the market in any amount. Unlike REACH there is no 1 tonne cut-off point. We understand that this also applies to R&D materials, inter-company transfers e.g. from outside the EU into the EU, etc.
There is a phase-in period for substances which have been on the market since 1st June 2007, which is open (at the time of writing) and will close for these existing substances on 22nd December 2010.
It will be possible to notify a substance under CLP if you are bringing it into the EU for the first time after 1st December 2010, and unlike REACH pre-registration this facility will remain open for the forseeable future.
Substances which are non-hazardous and do not have REACH-liability are exempt from CLP notification. Substances with a valid full REACH registration are deemed to have made CLP notification.
This new notification requirement will affect manufacturers and importers of substances in a way similar to REACH pre-registration, except that many more substances and companies will be affected because so many more will be brought into the scheme than under REACH by the fact that any amount qualifies (there is no lower threshold, in effect).
Click here to download your FREE factsheet listing the main categories of REACH-liable persons/ companies; and various “special cases”.
Please note that this factsheet is believed to be correct at the time of writing, but is not a substitute for reading the regulations, and taking advice on your own particular situation.
If you have any queries, contact us on 01422 24 22 22, or email email@example.com.
TT Environmental Ltd, July 2010