According to Article 45 of the CLP Regulation, manufacturers must send information on all hazardous mixtures to a national authority. In Germany this is the BfR.

For a transition period, the Safety Data Sheets of these products may be sent also to the ISi Information system of the Institute for Occupational Safety and Health (IFA) of the German employers’ liability insurance (DGUV). The transitional provision applies to § 28 (12) ChemG until 31.12.2019. From 1.1.2020 onwards, the reports are to be sent exclusively to BfR.

For consumer products, the notification also has to comply with the requirements of the new Annex VIII of the CLP Regulation, which was introduced by the EU Regulation 2017/542 of 22 March 2017, as from 1.1.2020. The message has to be made electronically in XML format using a Unique Formula Identifier (UFI).

The UFI must also be affixed to the product packaging, e.g. on the label. The XML schema will be developed by ECHA. UFI generation can be done via an online tool from ECHA or integrated into proprietary software. For commercially used mixtures, the aforementioned obligations apply from the 1.1.2021, and for mixtures for exclusively industrial use from the 1.1.2024.

For both ways of fulfilling the obligation in the current form, i.e. BfR notification (according to the BfR’s own specification) or ISI notification, Prosisoft offers the appropriate tools. Of course, such functionality can also be set up according to the requirements of other EU countries. You can find a list of national appointed bodies for the relevant countries here.