1. 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

2. 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
substances

3. 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

4. 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 ( )
~ 99 % of received notifications
Substances
Notifications
EC substances
33 %
70%
Non-EC substances
67 %
30%

5. Search options
echa.europa.eu 5

6. Substance summary page
echa.europa.eu 6

7. Harmonised classification - CLP
echa.europa.eu 7

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

9. 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

10. Examples of divergence
echa.europa.eu 10

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

12. 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

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

14. C&L Inventory and Seveso

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

16. 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

17. 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

18. 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?

19. 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?

20. Thank you!