C&L notifications (from the English terms Classification & Labelling) are among the core obligations arising from the CLP Regulation (EC) No 1272/2008, yet at the same time they remain one of the most frequently overlooked elements of regulatory compliance in the import of chemicals into the European Union. In practice, many companies incorrectly assume that this obligation applies only to large volumes or exclusively to entities registering substances under REACH. Such assumptions, however, may lead to tangible legal and administrative risks.

In this article, we explain when C&L notifications are required, why they constitute an obligation for every importer of chemical products, why they are not dependent on tonnage, and in which situations the impact of a substance on classification is of key importance.

What are C&L notifications?

 

A C&L notification is a formal submission to the European Chemicals Agency (ECHA) of information on the classification and labelling of a substance in accordance with the CLP criteria. This information is included in the public Classification and Labelling Inventory (C&L Inventory), which serves as the central database of information on the hazardous properties of chemical substances placed on the EU market.

The purpose of the C&L system is to ensure consistent and transparent communication of chemical hazards, both along the supply chain and towards enforcement authorities. In practice, the C&L Inventory is one of the key reference points used during inspections of chemical products, verification of safety data sheets, and assessment of the correctness of labelling. It also represents a valuable source of information for smaller companies that wish to classify their substances in accordance with the CLP Regulation—which is also their obligation if they import substances from outside the EU.

When are C&L notifications required?

 

The obligation to submit a C&L notification arises whenever an importer or manufacturer places on the market a substance that is subject to classification under CLP or that is subject to registration under the REACH Regulation. What matters here is the very act of placing the substance on the EU market and its hazardous properties.

In practice, C&L notifications are required, among other cases, for hazardous substances, substances subject to REACH registration, as well as substances which, when placed on the market as components of mixtures, have an impact on the classification of those mixtures. It is precisely this latter aspect that is most often overlooked by importers.

Obligations of chemical product importers

 

From the perspective of EU law, a chemical importer is treated as a manufacturer. This means that the importer bears full responsibility for the correct classification, labelling and notification of substances to the C&L Inventory. Documentation provided by a non-EU supplier may serve as a starting point, but it does not relieve the importer of the obligation to independently assess compliance with CLP requirements.

In practice, the obligations of chemical product importers include not only the preparation of safety data sheets and labels, but also the timely submission of C&L notifications to ECHA. This applies both to the import of pure chemical raw materials and to substances that are used as components of ready-made mixtures and placed on the market for further resale without any change to their chemical composition.

C&L notifications and tonnage – why quantity does not matter

 

One of the most common interpretative errors is the belief that C&L notifications depend on the quantity of the imported substance. However, the CLP Regulation does not introduce any tonnage thresholds in relation to this obligation.

Unlike REACH registration, where tonnage determines the scope of requirements, C&L notifications are based solely on the hazards arising from the intrinsic properties of the substance. This means that even the import of very small quantities—including sample, marketing or specialist quantities—may trigger the full obligation to notify classification and labelling.

When does a substance have an impact on classification?

 

Of particular importance in the context of C&L notifications is the concept of a substance’s impact on classification. The obligation to notify arises not only when a substance is marketed as such, but also when it determines the classification of a mixture in which it is used.

In simplified terms, a notification will generally be required when a substance is present in a mixture at concentrations exceeding the threshold values laid down in the CLP Regulation, for example:

• ≥ 10% for eye irritation,
• ≥ 1% for skin sensitisation,
• ≥ 0.1% for a substance classified as carcinogenic category 1B.

 

However, it must also be borne in mind that for properties such as acute toxicity, environmental hazards, or where specific concentration limits apply, the assessment of these requirements may be more complex

Deadlines and updates of C&L notifications

 

A C&L notification must be submitted within one month of placing the substance on the EU market. This deadline applies to the first placing of the substance on the market and is independent of the scale of the importer’s activity.

It is also important to remember that obligations do not end with a one-off submission. Any significant change in classification—for example resulting from new toxicological data, a change in composition (such as in the case of UVCB substances), or regulatory updates—requires an appropriate update of the notification in the ECHA system.

C&L notifications in the practice of chemical imports

 

In the context of importing chemicals into the EU, C&L notifications are often one of the first elements that should be verified even before regular deliveries begin. Errors or omissions at this stage can have a direct impact on the correctness of safety data sheets, product labelling and the overall compliance of documentation with the requirements of enforcement authorities.

Inspection practice shows that the absence of a C&L notification or an incorrect scope of notification is frequently one of the grounds for challenging a chemical product on the market. For this reason, the assessment of CLP obligations should be an integral part of any import strategy.

Summary

 

C&L notifications are a key element of the EU chemical safety system. They are an obligation for every importer of chemical products, independent of tonnage, and directly linked to the classification of substances and their impact on hazards.

In practice, a correct approach to C&L notifications not only ensures compliance with the formal requirements of the CLP Regulation, but also helps to reduce the risk of inspections, import holds, administrative sanctions and costly documentation corrections after the product has already been placed on the market.