Hazardous substances on the EU market The C&L Inventory and Platform as tools for self-classification and the application of the Seveso directive 23rd October 2013 Palmi Atlason Junior Scientific Officer European Chemicals Agency

Background Manufacturers/Importers are obliged to notify: (Art. 39) All hazardous substances (under CLP), and All substances subject to REACH registration… …which are placed on the market Notifications should contain: (Art. 40) Identity of the notifier Substance Identity (including composition and impurites/additives) Classification and Labelling (including SCLs/M-factors and reason for no classification) We have received so far (September 2013) 6.1 million notifications for 125.000 substances

The public C&L Inventory portal ECHA shall “establish and maintain a classification and labelling inventory in the form of a database” parts of which will be public (Art. 42(1)) REACH Article 119(1) Classification and labelling If applicable, EC name and no IUPAC name (+CAS no) (for certain hazard classes) Not included: Identity of notifiers Composition/Impurities/additives Confidential information Additional information: Table 3.1 to Annex VI of CLP joint REACH registration entry

Content of the Public C&L Inventory All notifications for substances for which there is a hazardous notification (according to article 119(1)) All notifications for EC substances Including non-classified substances ~ 92 % of notified substances (115.000) ~ 99 % of received notifications Substances Notifications EC substances 33 % 70% Non-EC substances 67 % 30%

Search options echa.europa.eu 5

Substance summary page echa.europa.eu 6

Harmonised classification - CLP echa.europa.eu 7

Convergence of classifications The C&L Platform and agreement on classifications

Divergence of classifications Notifiers of the same substance are obliged to “…make every effort to come to an agreed entry to be included in the inventory.” (Art. 41) ~ 27% of substances have different notified classifications Differences can be legitimate (e.g impurities/physical form), but different access to data or disagreement on data can also have effect Errors (e.g. missing labelling elements, incorrect hazard statement) are also common

Examples of divergence echa.europa.eu 10

Level of divergence in the Inventory Diverging classifications Diverging hazard statements Number of substances Number of aggregated classifications

The C&L Platform ECHA launched the C&L Platform in January 2013 to assist notifiers in agreeing on classifications of substances The Platform is a series of web-based discussion rooms, each connected to one substance on the C&L Inventory Each room accessible only to registrants and notifiers of that substance It is free, easy and anonymous and users are already discussing their substances

Is industry using the Platform? Currently 138 “active” rooms Activity per month Possible rooms 31.000 # rooms

C&L Inventory and Seveso

DSD classification and Seveso II Table 3.2 to Annex VI of CLP Seveso II categorisation of Annex VI entries

Seveso II and the Inventory Seveso II categorisation of Annex VI a one-off exercise Not updated and already out of date Seveso III based on CLP and GHS Applicable as from June 2015 Annex VI entries not fully harmonised Self-classification for other hazard classes obligatory Annex VI only contains a fraction of hazardous substances

Seveso III relevant substances Seveso category   CLP classification Substances Harmonised Notified H1 Acute Tox. 1 86 1045 P1a Unst. Expl. Expl. 1.1 Expl. 1.2 Expl. 1.3 Expl. 1.5 Expl. 1.6 53 154 P2 Flam. Gas 1 Flam. Gas 2 190 375 P6a Self-react. A Self-react. B Org. Perox. A Org. Perox. B 12 E1 Aquatic Acute 1 Aquatic Chronic 1 1212 15403 E2 Aquatic Chronic 2 600 5762

Seveso III and C&L Inventory Should Seveso III categorisation of Annex VI entries be included in the Inventory? Involvement of Seveso experts required Necessary to be kept up to date Annex VI entries incomplete and relatively few E.g targeted CMR proposals Notified substances a major concern High divergence of classifications problematic External “summary” Seveso III application?

Conclusions The C&L Inventory provides an overview of the EU chemicals market Some substances have divergent classifications “Clean-up” will take time Harmonised classifications and Seveso categorisations have been connected in the past Should this continue with CLP and Seveso III? Self-classifications now dominate the market How best to reflect that in the Seveso context?

Thank you! palmi.atlason@echa.europa.eu