Who must notify chemical substances according to the new CLP regulation?

We have made a simple drawing illustrating who must notify chemical substances according to the new CLP regulation.

Download the drawing here > Who must notify chemical substances according to the new CLP regulation?

Examples of who must make a notification

EU manufactures and importers (from non-EU countries) must make a notification.

Examples:

Manufacturer - a Danish company manufacturing enzymes (pure substances)

Importer - a Danish company importing paint from China (mixture) - the hazardous substances must be notified

Importer - a Danish company importing acetone from Argentina (pure substances)

Companies manufacturing mixtures - downstream users

Companies using chemical substances for the final product (mixture), or companies using chemicals as adjuvant in their final product must not notify, unless they are also importers from a non-EU country.

Substances which are solely imported for use in-house must also be notified (this also applies to substances and mixtures which are solely used for product development).

Example

A Danish company uses detergents clean their production equipment 

• Imported raw materials must  be notified
• Raw materials bought within the EU must not be notified (this responsibility is placed further back in the supplier chain).

Non-EU manufactures must not notify - this is the importer's job.

Companies decanting chemicals

These companies must not notify - unless they are also importers from non-EU countries.

Re-importers

You are a re-importer if all of the conditions below are fulfilled:

1. The re-imported substance is already registered (REACH) or notified before being exported out of the EU.
2. The substance is re-imported within the same supplier chain.
3. The re-importer can verify that the re-imported substance is the same as the one originally exported.
4. The re-importer can show documentation that the substance complies with REACH.

Distributors

The company does not have to make a notification - unless it is also an importer.

Recovery companies

Must notify - irrespective of the quantity.

Please contact us if you would like to know if your company is comprised by CLP and notification > Contact