From 1 July 2026, the European Chemicals Agency will publish the name of every company that has submitted a Classification and Labelling notification under the CLP Regulation. For the first time since the Inventory was established, the link between a substance, its self-classification, and the legal entity behind the submission will be visible to anyone with a browser. Lirk Nor helps manufacturers, importers and only representatives get their notified portfolio into a defensible position before that happens.
What a C&L notification is
A Classification and Labelling notification is a formal submission to ECHA under Article 40 of Reg. (EC) No 1272/2008, in which a manufacturer or importer declares the hazard classification, labelling elements and identity information for a substance placed on the EU market. The obligation applies to every hazardous substance placed on the market regardless of tonnage, and to non-hazardous substances subject to REACH registration. It must be submitted within one month of a substance reaching the market, and notifiers are expected to keep their entries current when classifications change, new hazard information becomes available, or new supply chains are established.
The notified data is consolidated in the publicly accessible C&L Inventory on ECHA CHEM, which today holds over seven million notified classifications and more than four thousand harmonised entries from Annex VI of CLP. Regulators, downstream users, customers, investors, civil society organisations and researchers consult it regularly. It is the principal public record of the hazardous properties of chemicals in the European market.
One thing worth clarifying: the notification obligation is not discharged by REACH registration. A C&L notification is required whenever no registration applies, and because there is no tonnage threshold for hazardous substances, even small-volume placements on the market trigger the duty. Where classification information has been submitted as part of a REACH registration dossier, the obligation for those substances is considered fulfilled, but every other route to market requires a separate Article 40 submission.
What changes on 1 July 2026
Reg. (EU) 2024/2865, published in the Official Journal on 20 November 2024 and in force since 10 December 2024, amends Article 42 of CLP and removes the anonymity that notifiers have relied on since the Inventory was created. From 1 July 2026, the name of every notifier will appear alongside the corresponding classification, together with the date the notification was last updated. Companies wishing to keep their identity confidential must submit a justified request through IUCLID no later than 30 June 2026, and confidentiality will only be granted where the legal criteria are met.
Once notifier identities are visible, the Inventory becomes a structured data source that third parties can query systematically. A downstream customer, an NGO, a sustainability analyst or an enforcement authority can, for any substance, identify who is placing it on the market, what classification they have assigned, how that classification compares with the most severe entry in the Inventory, and when the notification was last reviewed. Divergences between a company's notified classification and its SDS or product label become straightforward to surface. So does any inconsistency between group entities notifying different classifications for the same substance.
Organisations including ChemSec, the European Environmental Bureau, ClientEarth, HEAL and CHEM Trust have consistently used publicly available regulatory data to drive substitution pressure, investor engagement and supply chain scrutiny. The C&L Inventory, with notifier names attached, gives them a more granular tool than they have had before. Procurement functions in regulated sectors, trade press and ESG rating services will have the same access.
The practical implication is that a notified position which was once invisible is now an external-facing statement about a substance and the company that placed it on the market. A weak, outdated or inconsistent classification becomes a public liability rather than an internal compliance gap.
How LIRK NOR can help
LIRK NOR covers the full lifecycle of a C&L notification, with particular focus on the readiness work required before the July 2026 publication date.
Inventory audit and gap analysis
A LIRK NOR C&L audit reconstructs the complete notification footprint of the legal entity: missing notifications, submissions made by the wrong entity following corporate restructuring, and substances where the obligation was assumed to be discharged through REACH registration but was not. The deliverable is a substance-level status register that distinguishes compliant entries from those requiring action before 1 July 2026.
Pre-publication review and risk assessment
This is a focused review of every entry that will become attributable to the client on 1 July 2026. For each entry we assess the technical defensibility of the notified classification, its alignment with the most severe entry in the Inventory and with any harmonised classification in Annex VI, and the reputational exposure associated with the substance and its end-use context. The output is a prioritised remediation plan, together with a stakeholder briefing pack for legal, communications and executive teams.
Classification review and divergence justification
The amended Article 40 requires notifiers to justify any classification that diverges from the most severe entry already in the Inventory, or that proposes a more severe classification than those currently listed. LIRK NOR reviews the underlying science, drafts the justification in a form suitable for ECHA scrutiny, and where appropriate facilitates dialogue with other notifiers through the C&L Platform. The same workstream covers Acute Toxicity Estimates, M-factors, specific concentration limits, and the new hazard classes introduced by Reg. (EU) 2023/707, including endocrine disruptors, PBT and vPvB substances, and PMT and vPvM substances.
Confidentiality strategy and dossier submission
Where a notifier has a legitimate basis for keeping its identity confidential, we prepare the justification dossier, manage the IUCLID submission and track the ECHA decision. This service includes an honest assessment of the likelihood of success based on published criteria, and an analysis of whether confidentiality is the better path or whether a transparent position, supported by clear external messaging, would better serve the client's interests.
Notification submission, update and lifecycle management
For new substances entering the EU market, LIRK NOR prepares and submits the IUCLID dossier within the one-month statutory window. For existing notifications, a managed update service captures changes in classification, composition, supply chain structure, tonnage band and corporate identity. The service is built around the higher information demands of Reg. (EU) 2024/2865, including mandatory ATEs for all acute toxicity classifications and the requirement to record the date of last update.
Monitoring of harmonised classification and Annex VI developments
CLH proposals submitted to the Risk Assessment Committee give advance notice of substances facing classification changes. LIRK NOR monitors the CLH pipeline, RAC opinions, published ATPs and Commission delegated regulations, and translates them into substance-specific impact notes for the client portfolio, with enough lead time to allow for reformulation, supplier engagement or commercial repositioning where needed.
Alignment between notified classification, Safety Data Sheets and labels
A notified classification that diverges from the corresponding SDS or product label is the kind of inconsistency that becomes public on 1 July 2026. Take a substance classified as Repr. 1B in the Inventory but communicated as Repr. 2 on the SDS: once the notifier name is attached, that gap is visible to anyone running a systematic comparison. LIRK NOR cross-checks notified classifications against SDS content and label artwork, identifies these divergences, and supports the documentation update cycle required to bring them into alignment.
Group coordination and only representative arrangements
Multi-entity groups often have several notifying legal entities for the same substance, and only representative structures add further complexity around mandate documentation, group notifications and confidentiality. LIRK NOR reviews the group's notification architecture, recommends rationalisation where it improves consistency, and prepares the contractual and procedural documentation that ORs and importer groups are required to maintain.
Stakeholder engagement and external communications support
For substances or sectors where publication is likely to attract attention from civil society, downstream customers, investors or trade press, LIRK NOR supports the communications function with substance-level briefing notes, anticipated questions and answers, and third-party benchmark analysis. In coordination with our Brussels-based advocacy partner, we can also support structured engagement with policymakers and stakeholders where the topic warrants it.
Training and internal capability building
Workshops for product compliance, regulatory affairs, QA, advocacy and communications teams cover the operational implications of the CLP revision, the mechanics of IUCLID dossier preparation, the documentation requirements introduced by the new Article 40, and the cross-functional governance needed to manage notified positions in a public Inventory environment.
A note on Great Britain
For substances placed on the GB market, the notification obligation sits with the Health and Safety Executive under the retained CLP Regulation, with the GB CLP Agency replacing ECHA in that role. GB-based manufacturers and importers, and Northern Ireland-based suppliers placing qualifying Northern Ireland goods directly on the GB market, must submit to HSE within one month of placing new substances on the market. Substances covered by a transitional exemption for notifications already in the ECHA C&L Inventory on 31 December 2020, or by UK or EU REACH registration, do not require re-notification. GB CLP operates on the GB Mandatory Classification and Labelling list in place of EU harmonised classifications, and post-Brexit EU ATPs are not automatically adopted. LIRK NOR advises clients with GB-market exposure on the dual-track landscape and coordinates parallel submissions to HSE and ECHA where the supply chain requires both.
Work with LIRK NOR
The 30 June 2026 confidentiality deadline and the 1 July 2026 publication date are fixed. Companies that begin a structured pre-publication review now can still correct, update or claim confidentiality on entries before they become publicly attributable. The options narrow considerably as the deadline approaches.
Request a C&L pre-publication audit. A scoped engagement of two to six weeks, depending on portfolio size, delivering a substance-level register of notified positions, a defensibility and reputational risk assessment, and a prioritised remediation plan with clear ownership and deadlines.
Or speak to us about your wider regulatory programme. LIRK NOR also works across REACH registration and dossier maintenance, PFAS regulatory intelligence, microplastics restriction compliance, PCN poison centre notifications, and SDS authoring. A short introductory conversation is the most efficient way to identify where we can be useful.