Know your portfolio
Once you have identified an obligation and you are familiar with the standard information requirements, it is time to look at your product portfolio.
Firstly, identify which products have been previously notified and the countries where they are on the market. The language used in the submission has to be the language indicated by the Member State where the mixture is being placed on the market.
Establish the use type, or types, of each product, as this determines the relevant date of applicability and information requirements. There are three different use types:
- Consumer or professional – compliance date from January 2021
- Industrial – compliance date from January 2024
If a product has more than one of the above uses – whether through direct use or through its presence in a product re-formulated further down the supply chain – the earliest date of applicability applies (See step 1 ‘Know your obligations’). Effective communication both upstream and downstream in the supply chain ensures that all actors are holding all the current information about the mixture.
For mixtures used at industrial sites only, a limited submission is an option that allows you to provide information that, regarding the compositon, is limited to what is contained in the safety data sheet. Note that a safety data sheet in either a standard or limited submission is not an information requirement and the harmonised format must still be respected. However, if you use the limited submission option, you must provide a 24/7 phone number for rapid access to information in case of an incident.
You may be able to opt for a group submission, which brings multiple mixtures together under a single submission. All mixtures in the group submission must have the same classification for human health and physical hazards, and have the same mixture composition (though this can differ with regard to fragrances and perfumes under specific conditions).
Consider a voluntary submission for mixtures where there is no obligation to submit information, namely, non-hazardous mixtures or mixtures classified for the environment only. A voluntary submission may be useful if your product will be incorporated in a mixture that is classified as hazardous for human health and physical hazards. In this way, a voluntary submission can help protect your confidential business information such as the composition of your mixture, by allowing you to provide this information to your customers through the UFI only. Placing the UFI on the label would, however, be optional.