▪︎ CLP
C&L Notifications: Who Is Required to File, and What New Requirements Should Companies Be Aware Of Now?
The Classification and Labeling Notification (C&L Notification) is one of the key obligations under the CLP Regulation. In practice, however, it is often associated exclusively with manufacturers of substances. In fact, however, the notification requirement affects significantly more stakeholders along the supply chain. The CLP revision also introduced new transparency and updating requirements that companies should review now, if they haven’t already.
Who Must Submit a C&L Notification?
According to Articles 39 and 40 of the CLP Regulation, the obligation to notify the European Chemicals Agency (ECHA) applies to manufacturers and importers placing on the market hazardous substances that are subject to registration under REACH, either as substances on their own or in mixtures. In general, the notification must be submitted within one month of the substance being placed on the market for the first time.
In practice, it is often overlooked that the obligation is not limited to manufacturers or importers of substances. Companies manufacturing or importing mixtures or articles must also assess whether the substances they contain are subject to C&L notification requirements. This is particularly relevant when the substances concerned are not already covered by a registration or an existing notification submitted by the same company. Responsibility for compliance with the notification obligation always rests with the manufacturer or importer placing the product on the EU market.
Which Information Must Be Submitted?
The CLP Regulation specifies in detail which information must be provided to ECHA. This includes details on the identity of the company, the identity of the substance, the substance classification, and the relevant labelling elements. Where applicable, specific concentration limits, M-factors, and Acute Toxicity Estimates (ATEs) must also be reported. In addition, companies must explain cases where no classification has been assigned to certain hazard classes due to insufficient or inconclusive data.
The revised CLP Regulation has further expanded the requirements for C&L notifications. Companies must provide additional information and review existing notifications on a regular basis. Whenever new information becomes available or the classification of a substance changes, the submitted data must be updated without undue delay. ECHA may also proactively contact companies if entries appear incomplete, inaccurate, or outdated and request corrections.
ECHA Publishes C&L Notifier Company Names Since July 2026
A key change concerns the public transparency of the Classification and Labelling Inventory. Since July 1, 2026, ECHA has generally published the identity of notifying companies in the C&L Inventory. The objective is to improve the transparency of classifications and facilitate alignment between registrants and notifiers of the same substance. However, company names are not published if a justified confidentiality request has been submitted and accepted by ECHA.
Importantly, this requirement does not apply only to new notifications. Existing C&L notifications are also affected by the publication rules. Companies whose names are already publicly visible may still request confidentiality through an update of their notification, provided they can demonstrate that publication would harm legitimate commercial interests.
Considering these new requirements, companies should review their existing C&L notifications without delay. Our regulatory experts can support you with the assessment, updating, and compliant implementation of all obligations related to C&L notifications.
For more information, please contact us at sales@kft.de or use our contact form.
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