Submit a GB CLP substance notification
Some businesses must give HSE information about the chemicals they supply. This is called 'notification'. Notification applies to you if you are a:
- GB-based manufacturer or importer placing chemicals on the GB market
- NI-based manufacturer, downstream user or distributor supplying qualifying NI goods (QNIG) directly to the GB market
You must submit your notification to HSE within one month of placing new substances on the GB market. Your notification should contain information about the classification and labelling of the substance. This information will be included in the GB CLP notification database.
Notifications already made to ECHA and which are included in the ECHA Classification and Labelling Inventory on 31 December 2020, do not need to be re-notified. This includes notifications made by:
- GB-based manufacturers and importers
- non-GB-based manufacturers and importers whose substances were placed on the market in Great Britain
- NI-based suppliers, directly supplying the GB market with substances defined as QNIG
If you fall into one of these categories, your notifications will be recognised in Great Britain and you will not have to submit new notifications to HSE. However, you may be asked by enforcing authorities to provide information relating to the ECHA notification or to the REACH registration.
HSE wants to make sure that GB notifications are only made where necessary and companies avoid unnecessary re-notifications. A general exemption from notification is described in the Chemicals (Health and Safety) and Genetically Modified Organisms (Contained Use) (Amendment etc.) (EU Exit) Regulations 2020. It will operate as follows:
- where the GB or NI based supplier (supplying qualifying NI goods directly to the GB market) is an established manufacturer or importer, and has already notified the required substance information to ECHA for inclusion in the Classification and Labelling Inventory before 1 January 2021, no GB re-notification is needed;
- where a new GB based importer is part of an existing EU to GB/NI supply chain (as a downstream user or a distributor), in place on 31 December 2020, and the information already notified by the manufacturer or importer elsewhere in that supply chain can be relied on as accurate, no re-notification is needed. This avoids the problem of the inability of the GB based downstream user or distributor being able to access the original notifier's details which are not open to public view. The legal obligation to demonstrate that the information is correct will rest with the new GB based importer if challenged by a GB enforcing authority;
- where new supply chains are established from 1 January 2021, notification would be needed by the GB based manufacturers and importers, or by the NI-based supplier who supplies qualifying Northern Ireland goods directly to the GB market;
- where the hazard information in an exempted notification changes, a new GB notification is needed;
- where a valid UK REACH registration is in place, a GB CLP notification is not required and the obligation to notify is deemed to be fulfilled.
If the classification of the substance changes, then you will need to submit a notification to HSE. Otherwise, notification will only be needed where a substance is placed on the GB market for the first time after 31 December 2020.
The GB CLP notification database will contain new GB notifications received after 31st December 2020. The database is maintained by HSE.
Which substances must be notified under the GB CLP Regulation?
The substances which must be notified have not changed. Substances requiring notification are:
- substances subject to REACH registration and placed on the market
- hazardous substances placed on the market on their own
- hazardous substances placed on the market in a mixture, resulting in that mixture being classified as hazardous
Where substances subject to REACH registration have been registered under EU REACH prior to 31 December 2020 or under UK REACH after 31 December 2020, GB CLP notification is deemed to have been fulfilled.
Below are details of how you can:
- submit a new GB CLP notification
- update a previous existing ECHA notification
- update an existing GB CLP notification
How to submit a new GB CLP notification
You can notify by entering the required information on the GB notification web form.
You will need the following information to complete the notification:
- name, address and contact details of notifier
- identity of substance: Chemical name, IUPAC name, EC number and name, CAS number and name, alternative chemical name (if the IUPAC name is claimed confidential). For substances listed on EINECS, ELINCS or the NLP list, the ‘Chemical Name’ field should include the name from these lists. For plant protection and biocide active substances, the ‘Chemical Name’ should be the ISO name. Other names, such as usual or common names may be included in some cases. Otherwise, the ‘Chemical Name’ should be the IUPAC name
- molecular/structural formula, nature of substance (i.e., mono-constituent, multi-constituent or UVCB), composition (i.e., purity, impurities and/or additives that contribute to the classification)
- classification: hazard class and category code(s); hazard statement code(s); indication if the substance has mandatory classification and labelling and whether the classification is affected by impurities and/or additives
- justification for absence of classification (if applicable). For those hazard classes and differentiations for which the substance is not classified it is necessary to indicate whether this is due to data lacking, inconclusive data or data which are conclusive although insufficient for classification. In the notification form, default entries for no classification (data lacking) can be added by clicking the button ‘add entries for no classification’. These automatic entries can be amended accordingly to ‘inconclusive’ or ‘data conclusive but insufficient’ as necessary by selecting the entry and then the ‘edit’ button
- specific concentration limits, M-factors and/or acute toxicity estimates (ATE) - if applicable
- labelling; signal word, hazard pictogram(s) and pictogram code(s), hazard statement(s) supplementary hazard statement code(s) (if applicable)
Certain information from the GB CLP notification database will be made publicly available in due course.
In the event that the webform is unavailable, submissions to the GB CLP notification database can be made using the GB notification database template (see below) and emailing to [email protected].
How to update a previous existing ECHA notification
Updating a previous existing ECHA notification in the UK will need to follow the same process as submitting a first-time GB notification for a substance new to the GB market. Notifiers should fill in the webform as indicated above.
How to update an existing GB CLP notification
The procedure for updating an existing GB CLP notification is different from that described above. Instead of submitting the webform, notifiers should fill in the template below and email to [email protected].
For help with notifications, contact us at [email protected].
The online GB CLP notification webform and GB CLP notification database and the General Data Protection Regulations (GDPR)
This information is given to HSE under a statutory obligation so that HSE can fulfil its public functions.