The deadline falls under Annex VIII of the classification, labelling and packaging (CLP) Regulation, which require importers and downstream users to notify national appointed bodies if they are placing hazardous substances on the market, specifically for consumer use, by this date.

At recent meetings of the competent authorities for REACH and CLP, trade associations and member states have been commenting on the requirements. After a meeting on the 12th June, a paper was published in which Cefic said that with 18 months to go, the Commission would be unable to “deliver results for a quality workability study” and solve “highly important issues”.

The workability study was launched shortly after the Cefic paper and will address stakeholder concerns over the practicalities of new requirements on the submission of information. The year-long exercise is to focus on industries with complex material inputs and supply chains and propose solutions to the problems raised. Interim results will be discussed in the study steering group and stakeholder advisory group at the start of 2019.

Cefic said it anticipates the study will “demonstrate the need for amending the text of the annex to make it workable”. It added that progress on the Echa notification portal has been “slow” and the decision to develop an agency database is “still open”.

The trade body also said that the time allowed for building the poison centres notification (PCN) format and the delays the pilot projects have suffered make the proposed dates unrealistic for such a complex project. Industry, it said, will need to dedicate “considerable resources” to comply with Annex VIII and therefore it “cannot accept” the use of “overcomplicated” tools.

Cefic considers that it would be impossible for companies to prepare for compliance with this amount of uncertainty remaining over basic features.

The notification deadline for companies marketing substances for professional use is 1 January 2021, and for industrial use 2024.

Member states

It is reported that some member states are considering the possibility of hosting their own database in case Echa does not have a centralised one in place.

Member states are also preparing to include national requirements, which according to CEFIC, would make the exercise of harmonisation “completely futile”. Cefic has asked the Commission to convey this message to member states to “ensure alignment”.



The amendment can be accessed here, and can be downloaded as a PDF (in English): Annex VIII

Unique Formula Identifiers (UFIs).


Hibiscus Plc is ready to support you with the authoring of Safety Data Sheets and production of product labels to allow a smooth transition into compliance for 2020 onwards.


CALL US regarding your labelling requirements on 0113 242 4272