REACH - CLP regulation: notification of classification and labelling of Portland cement clinker

The CLPⁱ Regulation, a comprehensive new system for the classification, labelling and packaging of hazardous substances and mixtures adopted in December 2008, requires substances to be classified, labelled and packaged according to the new system as of 1 December 2010. In addition, the regulation also requires the C&L (Classification and Labelling) to be notified to ECHAⁱ (The European Chemicals Agency, C&L inventory) by 3 January 2011 at the very latest for hazardous substances which were placed on the market before 1 December 2010.

The notification has to be made by companies (legal entities) which place a hazardous substance on the market. This covers both EU manufacturers and importers of a hazardous substance from outside the EU and applies to substances on their own or in a mixture.

In practice, this means that cement companies (legal entities) which either produce Portland cement clinker and place it on the market in the EU (on its own or in cement) or import it (again on its own or in cement) need to notify the C&L of Portland cement clinker to ECHA by 3 January 2011. The notification obligation does not apply to mixtures (such as cement or other mortars) as such.

The notification can, however, be carried out for a group of manufacturers or importers, instead of each individual company having to make the notification. CEMBUREAU is thus organising the notification of the C&L of Portland cement clinker on behalf of cement companies. In order to be able to do so, the Secretariat needs to collect the following for each individual legal entity which wants to adhere to the notification:

• Name and identifier of the legal entity/notifier. The identifier can be a VAT number or a UUID of a REACHⁱ-IT account.
• Contact person for the legal entity.
• Explicit agreement with the classification of Portland cement clinker under the CLP Regulation as approved by the CEMBUREAU Board on 28 September 2010.
• Explicit agreement that CEMBUREAU can carry out the notification on behalf of the legal entity.

Alternatively, companies can also make the notification themselves, but they have to wait until after the initial notification has been made by CEMBUREAU.

Cement companies requiring more information should contact either their national cement association or c.roeland@cembureau.eu as soon as possible.