EU Inventories

C&L Inventory

The Classification and Labelling Inventory (C&L) contains classification and labelling information for substances notified under CLP Article 40 and registered under REACH. The inventory also contains the list of harmonised classifications (Annex VI of the CLP), which are legally binding in the EU. The entries for each substance include the IUPAC nomenclature, the name as given in EINECS (if applicable), and the classification and labelling of the substance.

Harmonised Classifications

The C&L Inventory includes the list of harmonised classifications. These classifications are from CLP Annex VI and are legally binding in the EU. When a harmonised classification is available it classification appears at the top, while the notified classifications can be found underneath.

Notified Classifications

The Inventory also lists all classification and labelling information for substances that have been notified or registered. Although the C&L Inventory strives to reduce the number of classifications, this portion of the inventory may display many different classifications for the same substance. These variations could occur for several reasons. For example, substances could have slight differences, such as physical states or formulations, or notifiers could draw different conclusions due to discrepancies in the data used. Although ECHA includes these classifications in the C&L Inventory, they do not review or verify their accuracy.

The notified classifications are organized as follows:

  • Entries are grouped together by numerical identifiers – such as CAS or EC number
  • Classifications from joint REACH registration submissions are flagged accordingly
  • Identical entries for the same substance are consolidated and indicate the number of notifiers

Seveso Categories

The C&L Inventory also contains categorisation of harmonised substances according to the Seveso III Directive.

Seveso III (which repealed Seveso II), describes rules for the prevention of major accidents involving hazardous chemicals. In accordance with this Directive, chemicals are categorised based on their hazardous properties and as a result, specific rules regarding storage and handling apply.

EC Inventory

The EC Inventory is a consolidation of 3 lists: EINECS, ELINCS and the NLP list. Notification to these inventories is not required and the lists are static. However, presence on the inventory is still relevant for substance identification and related REACH registration deadlines.  

EINECS: European Inventory of Existing Commercial Chemical Substances

The European Inventory of Existing Commercial Chemical Substances (EINECS) was published officially in English in 1988. It was later published in all nine EEC (European Economic Communities) languages in June 1990, and a corrigendum was published on March 1, 2002.

EINECS is an inventory provided by the EEC of “existing substances” that were reported to be on the EU market between January 1, 1971 and September 18, 1981. This list is static by design, thus it is not possible to add substances. EINECS contains over 100000 entries and is now stored on the European Chemical Agency (ECHA) website as part of the consolidated EC inventory.

ELINCS: European List of Notified Chemical Substances 

The European List of Notified Chemical Substances (ELINCS) contains substances that were notified as new under the Dangerous Substance Directive 67/548/EEC notification scheme. As of June 1, 2008, the notification scheme was repealed and replaced by REACH.

The publication of ELINCS as part of the consolidated EC inventory contains the name, EC number, CAS number, and a description, e.g. the trade name. Prior to consolidation, this inventory also contained classification information. For more than half, the authorities agreed to preserve confidentiality by omitting the full chemical name (and CAS number). Minor components and impurities were not mentioned in ELINCS unless there was indication that they contributed to the classification of the substance.

NLP: No-Longer Polymers List

The No-Longer Polymers List (NLP) is not considered an inventory. This list arose as an aid to navigating the special rules, notification requirements, and reporting requirements for existing substances under EU Directive 67/548/EEC as amended through the 7th amendment, EU Directive 92/32/EEC.

The 7th amendment redefined polymers. In this new definition, molecular weight of the substance was taken into account, better aligning with criteria commonly used in the scientific community. This changed the regulation of many substances formerly considered polymers. As such, the NLP list contains substances that were:

  • previously polymers under EINECS reporting rules, but were no longer polymers due to the change in definition AND
  • present on the European market between September 18, 1981 and October 21, 1993

These substances were not retrospectively subject to notification requirements; however, they now require registration under REACH.

Note that the NLP list is not exhaustive. On a case by case basis, Competent Authorities allowed the “no-longer polymer” designation for substances not on the list that met the no-longer polymer criteria.

Sources

Consolidated EC Inventory

EU Directive 67/548/EEC

EU Directive 92/32/EEC

EC Number Guide

EINECS: 2XX-XXX-X or 3XX-XXX-X

ELINCS: 4XX-XXX-X

NLP: 5XX-XXX-X

ECHA uses EC numbers as the primary method of identification for substances in the EC inventory. Similarly, list numbers (6XX-XXX-X, 7XX-XXX-X, and 8XX-XXX-X) identify substances not in the inventory. Unlike EC numbers, list numbers have no legal standing.