DEKRA reminds you of the imminent reporting obligation for hazardous substances

Additional information for poison control centers

Apr 10, 2019

Starting in 2020, companies that place mixtures (“chemicals”) on the market must notify the authorities of each consumer product. The goal is to make information on potentially hazardous substances that consumers may come into contact with transparent for public institutions, such as poison control centers. The expenditure for manufacturers will be significant. DEKRA’s hazardous substance experts advise the companies affected to immediately prepare for the reporting obligation.

The scope of the reporting obligation is defined in Annex VIII of the CLP regulation. The reports require a lot of preparation – including the generation of UFI codes for each formulation. The new reporting obligation pursuant to Art. 45 of the CLP regulation (Regulation (EU) no. 1272/2008) calls for information that is more comprehensive than previously with Section 16e of the Chemikaliengesetz (German Chemicals Act). A key difference from the previous practice is that the entire formulation must be reported: A UFI (Unique Formula Indicator) must be generated for each formulation as well as indicated on the label and on the safety data sheet.
Formulators and importers therefore rely on the preliminary work of their suppliers. For this reason, companies that have not taken an active role in the matter should start planning immediately, advises DEKRA. The preparations are extensive:
  • Clarify which formulations the company is concerned with.
  • Check its own formulations and ask suppliers for additional information.
  • Assign product categories according to the new rules.
  • Gather, review, and (if necessary) improve all reportable information.
  • Coordinate with the company to determine how the UFI can be integrated into the product label
  • Generate UFIs.
  • Carry out product reports.
In this regard, it makes sense to revise and update your own safety data sheets. Experience has shown that many companies, especially SMEs or importers, have only limited capacities to complete these activities in a timely manner. If this is the case, it may be advisable to get external support.
DEKRA’s experts have more than 25 years of experience in advising companies on legal issues relating to hazardous substances and in drawing up safety data sheets for a number of industries.