ECHA

Up-to-date information on registration, harmonised classification as well as authorisation and the restriction status of substances is important to downstream users for both economic and safety reasons. Do you know how to find this information on ECHA's website?

ECHA held a webinar in September 2013 giving an overview of how to find information about chemicals on ECHA's website. Tips were also given to support downstream users to know when they need to take action and on how they can use the information to comply with their obligations. More than 300 industry professionals from 24 EU and non-EU countries joined the open, free-of-charge webinar.

During the event, participants asked many interesting questions. We now share some of them with you. The questions and answers related to certain topics have been merged to increase clarity.

Q: Is the information of all registered substances open to the public or are there some restrictions (like legal or supplier's restrictions)?

A: All of the non-confidential information on registered substances is made public by ECHA in accordance with Article 119 of REACH, which specifies which information is always to be published, and which can be claimed confidential. 

Q: Can the information published be used for purposes other than REACH? How can I contact the data owner, who is not identified on ECHA's website?

A: The data from dossiers is published on ECHA's website for general information purposes. Any other use of the information without obtaining the permission from the owners might violate their rights. To contact the data owner, you need to send your question through the ECHA Helpdesk contact form for the specific data you need.

Once you have permission from the data owner, you can use the data.

Q: Why is the harmonised classification sometimes different from the registered or notified classification?

A: Differences between harmonised and registered or notified classifications can have different origins.

A substance which is subject to harmonised classification and labelling (Part 3 of Annex VI to CLP) must be classified in accordance with that entry. In addition, the manufacturer or importer should self-classify the substance for those hazard classes where no harmonised classification is available. For example, a substance may have a harmonised classification for acute oral toxicity, but not for acute dermal toxicity. This means that the manufacturer or importer would have to use the available harmonised classification and then explore, using the information available, whether the classification criteria for acute dermal toxicity are fulfilled, and classify accordingly.

The resulting classification and labelling should be introduced in the notification the manufacturer or importer submits to the Classification and Labelling Inventory.

Self-classification can depend on the data each supplier has access to or on the impurities present in the substance. Therefore, differences in self-classification can have a firm basis.

For substances with a minimum harmonised classification (classification marked with an asterisk in Annex VI to CLP), notifiers must also classify them in a more severe hazard category if they have information showing that this is more appropriate. Again, the result of this classification will depend on the data the notifier has access to and may give rise to different classifications.

Q: Which classification must I use if I have two suppliers who have different classifications in their safety data sheets and there is no harmonised one?

A: Downstream users may use the classification from one of their suppliers or otherwise they must self-classify the substance and notify ECHA.

We recommend that you contact your suppliers to clarify and agree on a classification, if possible. There could be justified reasons, such as impurities, that explain the difference.

If no agreement can be reached we recommend taking a cautious approach and using the more severe classification.

Q: What is the Registry of Intentions (RoI)?

A: Member States or ECHA (on request of the Commission) can initiate for a substance:

• identification of substances of very high concern; or
• restriction.

In addition, Member States or manufacturers, importers or downstream users may submit proposals for harmonised classification and labelling.

Intentions to initiate these processes are notified to ECHA and can be found on ECHA's website in the RoI. The aim of the public Registry of Intentions is to inform interested parties of authorities' planned activities well in advance of the actual submission of the dossiers. This helps them to prepare in time for the commenting and for the possible future regulatory requirements.

Q: Are there fixed dates for updating the list of harmonised classification and labelling, Classification and Labelling Inventory, Candidate List, Authorisation List (Annex XIV) and the List of Restrictions (Annex XVII) or must they be monitored continuously?

A: The list of harmonised classification and labelling and the Authorisation List of REACH are updated about once a year and the List of Restrictions whenever a new restriction has been agreed and published. The Candidate List is updated twice a year, in June and in December.

The Classification and Labelling Inventory is updated about once a month.

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These are only a few of the questions that were raised during the webinar. If you wish to find out more about the event, check out the recording and presentations. 

The webinar received a very positive feedback with 93% of the respondents being satisfied or very satisfied with the overall effectiveness of the webinar.

Further information:

• Questions and answers
• Downstream users 
• National helpdesks providing support
• ECHA Helpdesk contact form 
• Registry of Intentions 

Upcoming webinars   12 February 2014 How to bring your registration dossier in compliance with REACH – Tips and hints (part 5)   This webinar provides feedback to registrants on how to submit information on chemicals in the technical dossier to ECHA in compliance with REACH.   Q1/2014 How to ensure the safe use of nanomaterials under REACH, part 3: Exposure and risk assessment   Q4/2014 How to bring your registration dossier in compliance with REACH – Tips and hints (part 6)   Further information

Text by Monique Pillet