Submitting CLP Notifications

Based on the transition period regulated in the accession treaty to the EU, Croatian companies had to fulfil the notification requirements according to Article 40 of the CLP regulation until 1 August 2013. Until the end of this deadline, 12 companies have submitted more than 3000 notifications to the Classification and Labelling (C&L) Inventory which means an average of more than 250 notifications per company.

The obligation to notify applies to all substances that are subject to registration (manufactured or imported > 1 ton) as well as to manufactured or imported substances classified as dangerous < 1 ton as such or in a mixture. It does not apply to substances where the information on classification and labelling has already been submitted as a part of the registration dossier.

Although the obligation for notification to the C&L inventory applies already since 1 December 2010, many EU based companies, especially importers of substances that are not subject to registration or that still benefit from an extended deadline, are not aware of this requirement at all.

Companies not acting in accordance with this regulation may be fined as there are direct sanctions in place in the member states. In Germany, e.g. up to € 50.000 can be fined in case a notification is not submitted at all, not in time, not correctly, incomplete, not in the format requested or not updated according to harmonized classification decisions.

Notification is free of charge and can be easily submitted via REACH-IT.