20Th Meeting of Competent Authorities for REACH and CLP (CARACAL)

Helsinki, 24/02/2016 Doc. CA/12/2016

20th Meeting of Competent Authorities for REACH and CLP (CARACAL) 8-9 March 2016 Room MANS, CHARLEMAGNE building Brussels

Concerns: C&L inventory pilot project to increase the convergence in self-classifications (Art 41 CLP Regulation): follow up

Agenda Point: 12.6

Action requested: The CARACAL are invited to take note of this document for discussion. Written comments on this document should be sent by 8th April to Roberto Scazzola ([email protected]) and Ricardo Simoes ([email protected]). Summary

This document informs about the follow up actions taken and planned to encourage companies to agree on the classification and labelling of their substances in the C&L inventory, according to the requirements set out in Article 41 of the CLP Regulation. For the background and previous activities, please, see CARACAL documents CA/104/2014 and the report on the C&L inventory pilot project, provided for the 19th CARACAL (CA/45/2015).

Follow up actions to enhance the convergence in self-classifications

More user-friendly overview of the harmonised and self-classification on ECHA website

ECHA’s dissemination site provides an overview of the harmonised and self-classifications. Since beginning of this year a summary of classification and labelling is available in the substance specific info-cards and more detailed information in a brief pro- file, which also shows the level of agreement in self-classification.1 Different classifications are now made more apparent than before. This may provoke companies into spontaneously reviewing their classification.

Practical advice on how to update C & L notifications

A brief overview on how to update the C&L notification using any of three notification tools provided by ECHA (the online tool in REACH-IT, bulk tool and IUCLID C&L notification), including step-by-step instructions for each of these tools, have been draf- ted in co-operation with industry stakeholders and will be made available on ECHA’s website.

Targeted letter campaign

A letter campaign similar to the actual pilot project of 2015 will be launched in the beginning of March. This will cover ten substances which industry stakeholders proposed for the second round. Letters will be sent to all notifiers and registrants of these substances (~ 2700). The aim is to draw their attention to the divergent classifications and to urge them to agree.

Awareness raising

The task group proposes to carry out communication activities to raise awareness of the importance of correct and agreed self-classification.

The main challenge is to reach and have an impact on notifiers who have no other REACH obligations. This group of duty holders is wide and diverse. Therefore, it is proposed to take joint communication activities to reach out to them. It is suggested that the Member States, the Commission, ECHA and ECHA’s Accredited Stakeholders work together on this on a voluntary basis.

Members of the existing task group (representatives from COM, CEFIC, EuroMetaux, FECC and ECHA) could form the core of the new communications working group, but an invitation should also be extended to Member States and ECHA accredited stakeholders. As with the other similar communication activities, ECHA would coordinate the work of the group. The objective of the group would be to establish and implement a joint strategy and plan to provoke companies into agreeing on their classifications. To allow sufficient time to establish the group, develop the strategy, prepare the material and translate it, the work would commence this year, with a

1 http://echa.europa.eu/information-on-chemicals

2 launch of the activities planned for 2017. This work should build on the planned REACH 2018 communication activity – when new registrants are considering their own self-classification.

The communications working group could take its model from similar joint activities in the past and currently underway – current joint communication projects for example include the REACH 2018 work and reaching out to workers.

Action requested The CARACAL members and observers are invited to provide comments to the following actions by next 8th April 2016 to Roberto Scazzola ([email protected]) and Ricardo Simoes ([email protected]):

1) to discuss and agree on initiating and participating in joint communication activities

2) to provide any existing material which could be used as a basis for the awareness raising material.

3) to volunteer to join the communication working group for planning, preparing and steering the project.