Classification and Labelling Inventory (C&L)

The Classification and Labelling (C&L) Inventory is a database maintained by the European Chemicals Agency (ECHA). The C&L Inventory lists classifications and labelling elements of dangerous substances placed on the market in the European Union (EU) by manufacturers or importers. Classifications and labelling elements of pure substances must be notified. The legal basis for the obligation to notify classifications and labelling elements to ECHA is set out in the CLP Regulation (Articles 39 to 41). The C&L Inventory is publicly accessible.

The ECHA website states explicitly that ECHA does not verify the accuracy of the information in the C&L Inventory. The C&L Inventory now contains numerous different classifications for most substances. Possible reasons for this include impurities or additives, and the form or physical state in which the substance was placed on the market. However, the possibility cannot be excluded of incorrect classifications also being reported to the C&L Inventory by manufacturers/importers owing to a lack of data or information.

The reasons for discrepancies in classifications and labelling elements of a substance cannot normally inferred from the C&L Inventory. If you are looking for information on the classification and labelling of pure substances, you are therefore advised to use the data in the C&L Inventory with caution and, where possible, also to consult other sources. For example:

  • The ECHA database of registered substances contains data from the registration dossiers of all registered substances. The database also contains classifications of the registered substances, and you can verify on what basis the substances were classified.
  • You can search the Internet for safety data sheets of well-known manufacturers. Many manufacturers publish their safety data sheets on their websites.
  • The GESTIS substance database contains classifications and labelling elements for a large number of pure substances. The classifications and labelling elements are sourced from manufacturers or the registration records and adopted following a plausibility check.
  • What substances must be notified in the C&L Inventory?

    Substances for which registration is mandatory

    The classifications and labelling elements submitted to ECHA in the course of registration are also transferred to the C&L Inventory, irrespective of whether or not the substance is labelled dangerous or not classified.

    Should you, as a manufacturer or importer, already have notified ECHA of classification and labelling elements of a substance in the course of the registration process, you do not need to submit an additional notification to the C&L Inventory (REACH, Article 40 (1)).

    Substances within the scope of Article 1 of the CLP Regulation

    The classification and labelling elements of a substance that is not subject to registration under REACH (for example because less than one ton of the substance is manufactured or placed on the market per year) must also be notified to the C&L Inventory if the substance falls within the scope of Article 1 of the CLP Regulation and is classified as dangerous.

    Should dangerous substances be placed on the market in a mixture, they are subject to notification only if they contribute to the hazard classification of the mixture (see below).

  • What are the deadlines for notification?

    Any manufacturer or importer placing dangerous substances on the market in the EU is obliged to notify ECHA of the classifications and labelling elements of the substances concerned. Notification must be submitted no later than one month after the dangerous substance has been placed on the market.

    Should you be an importer of a mixture containing a dangerous substance above the concentration limits stated in Annex I of the CLP Regulation, which thus causes the mixture to be classified as hazardous, you must notify ECHA of the classification and labelling element of this substance after placing the mixture on the market.

    Should you be an importer of an article containing substances subject to registration under Article 7 of the REACH Regulation, you must notify these substances. Since substances must be registered before they are placed on the market, statement of the classification and labelling element in the registration dossier is sufficient for compliance with the obligation to notify them for the C&L Inventory.

  • Who is not subject to an obligation to notify with regard to the C&L Inventory?

    Should you be an importer of an article containing only substances not subject to registration, you are not required to notify these substances to ECHA or the C&L Inventory.

    Downstream users such as formulators of mixtures, producers of articles and distributors of dangerous substances and mixtures are likewise not subject to the obligation to notify. In these cases it can be assumed that the substances have already been notified at an earlier stage in the supply chain.

Wording of

Original text of the REACH regulation and its amendments (PDF, 109 kB, non-accessible)