Registration vs. Notification of Substances – When and What You Must Comply with Under REACH and CLP

If you manufacture or import chemical substances or mixtures into the EU, you are likely to encounter the terms notification and registration. At first glance, these terms may sound similar, but they are two separate processes.

Both obligations relate to European legislation, but their purpose, scope and complexity differ. This article will clearly explain the difference between notification under the CLP Regulation and registration under the REACH Regulation.

What is substance registration (REACH)?

Registration is a requirement of the REACH Regulation (No. 1907/2006). Compared to notification, it is a more complex and extensive process intended to ensure that a chemical substance does not pose a threat to human health or the environment.

When is registration mandatory?

Registration must be carried out by any manufacturer or importer who places a substance on the market in a quantity greater than one tonne per year. The obligation applies to substances on their own, in mixtures, and in some cases to substances in articles. Substances already regulated by other legislation (e.g. pharmaceuticals, radioactive substances) are partially or fully exempt from REACH. A substance must not be manufactured or placed on the EU market without proper registration.

What does registration involve and how is it carried out?

Registration requires the preparation of a so-called registration dossier, which includes substance identification, hazard data, physico-chemical properties, toxicology, ecotoxicology and exposure scenarios. Where necessary, a risk assessment must also be provided, outlining the potential risks of using the substance and how these risks should be managed.

Registration follows the principle of "one substance, one registration". This means that manufacturers and importers of the same substance must submit a joint registration. The submitted data must be consistent and sufficient to confirm the identity of the substance. A fee is usually charged for substance registration.

What is substance notification (CLP)?

Notification is a process based on the CLP Regulation (No. 1272/2008). Its aim is to ensure that the European Chemicals Agency (ECHA) has information on the classification and labelling of substances placed on the EU market. Information about substances is published in the so-called C&L Inventory on the ECHA website.

This is a database that contains not only information on notified and registered classifications and labellings, but also a list of harmonised classifications (Annex VI to the CLP Regulation) and the names of harmonised substances translated into all EU languages. The ECHA hosts the database but does not verify or review the accuracy of the information.

When is notification mandatory?

Notification must be carried out by any manufacturer, importer or representative who places a substance on the market either on its own or in a mixture, if the substance is classified as hazardous or subject to registration under REACH (regardless of its hazard).

What is the notification deadline?

The deadline is one month from the first placing of the substance on the market.

Does quantity matter?

Unlike registration, notification is not dependent on quantity, and must be done even below 1 tonne/year.

Notification updates

From 1 July 2026, there will be a change in the way information is published in ECHA’s C&L Inventory. Currently, notification is anonymous – the public cannot see who submitted the classification. From July 2026, the name of the entity (e.g. company name) responsible for the classification will be published with each notification. If a group of manufacturers or importers submits a joint notification, the name of the acting party will be published. ECHA will also allow companies to request confidentiality of their name – specific guidance will be provided.

Conclusion

Notification serves to inform about hazardous properties and labelling of substances. It is not linked to risk assessment or substance quantity. Registration applies to quantities ≥ 1 tonne/year and is significantly more demanding. Its main goal is to ensure the safe use of chemicals.

Both obligations are essential for the safe management of chemicals on the European market.

Note: This article is for informational purposes only and does not replace applicable legislation.

Recommended sources:

• REACH Regulation (EC) No. 1907/2006
• CLP Regulation (EC) No. 1272/2008
• ECHA Registration
• ECHA C&L Inventory