Notification of hazardous mixtures in France – Deadline 1 January 2019

Chemical product manufacturers, importers or distributors placing products on the French market are required to notify certain products to the INRS (Institut national de recherche et de sécurité).

The French Decree No 2014-128 on toxicovigilance defines those hazardous chemicals that need notification according to a schedule running until June 2022.

The next deadline is 1 January 2019. Companies needing to notify their product(s) should immediately begin the process.

Mixtures needing notification

Notifications are mandatory for biocidal products as well as for hazardous mixtures classified for acute toxicity – categories 1, 2 or 3, specific target organ toxicity (single and repeated) – category 1, CMR 1A, 1B or 2, skin corrosion – category 1, skin sensitisation – category 1 and respiratory sensitisation – category 1.

In addition, from 1 January 2019, all mixtures classified as hazardous to health according to the CLP classification below will need to be notified:

• Acute toxicity, category 4 (H302, H312, H332)
• Specific target organ toxicity – single exposure, category 2 or 3 (H371, H335, H336)
• Specific target organ toxicity – repeated exposure, category 2 (H373)
• Aspiration toxicity, category 1 (H304)
• Reproductive toxicity, additional category: effects on or via lactation (H362)
• Serious eye damage, category 1 (H318)
• Eye irritation, category 2 (H319)
• Skin irritation, category 2 (H315)

Health products for humans, cosmetics products, veterinary medicinal products, radioactive substances and mixtures, foodstuffs/feedstuffs and their components and waste are exempt from the notification.

How TSG can help

Notification must be done online using a secure website that requires an electronic authentication certificate, which has proved challenging for companies not based in France.

TSG has the required electronic authentication certificate and can act as third party to notify your mixtures. Our team of consultants has many years of experience notifying mixtures and updating the information using these web-based tools for submitting notifications to INRS.

If our services are of interest, or if you would like to find out more information, please contact us at [email protected].