All companies that import or produce hazardous chemical products for professional use in Denmark must notify the Product Registry of the products. Learn which substances and materials, that are covered by the obligation to notify.
If your company manufactures, imports to Denmark or changes the trade name of any hazardous material in quantities equal to or exceeding 100 kg per year, you have a duty to notify to the Product Registry.
For pure chemical substances used for commercial purposes in quantities equal to 100 kg up to 1000 kg per year you also have a duty to notify, if the substances are not covered by the notification to REACH.
Companies must notify the following substances and materials to the Product Registry. The list is based on Arbejdstilsynet's definition of hazardous:
In addition to this you can notify raw materials, biocides for private use or in quantities less than 100 kg a year and products for use offshore. For more information, see below.
NAVIGATION
You do not need to notify the following substances and materials in the Product Registry:
Liquid substances and materials that only fall under the duty to notify due to their content of one or more of the following substances from the Executive Order on Limit Values for Substances and Materials (in Danish):
The Product Registry is a joint registry under the Danish Working Environment Authority and the Environmental Protection Agency. The registry includes information about the products trade name, composition, danger labels, quantity manufactured or imported as well as use, e.g. purpose and sectors.
The authorities is using the information in the Product Registry to monitor the use of hazardous substances and materials, e.g. the use of carcinogenic substances in specific sectors. The Registry contains information on approx. 40,000 notified products.
Information in the Product Registry is subject to high security in accordance with the regulations in the Executive Order on the Registry for Substances and Materials. Companies only have access to their own confidential information. This access requires a two-factor login and all communication to and from the system is encrypted.
The Product Registry stores the information physically in a secure archive facility in Arbejdstilsynet, and electronically in the Probas database. Only employees with special clearance have access to information in Probas.
When you have notified a product, it is assigned a so-called PR number. You must state the PR number on the product's packaging no later than one year after it has been assigned.
A PR number is not an approval of the substance or material, but only proof that the substance or material has been notified to the Product Register.
If there are significant changes to the information you have previously submitted, you must update it. This could be changes in the composition, change of importer or adding a new importer or if the import or manufacture of the substances and materials are terminated. It is also considered a significant change if the product's labeling changes or it is no longer required to be labeled.
You must also update the Product Registry if the legal status of the company changes, e.g. if the Danish importer is issued with a new CVR number or your company changes it's name or location.
Updates must be made online.
Once you have notified a product to the Product Register, you will be asked to submit information on the quantities actually produced or imported every two years. You will receive a letter when it is time to report.
It is the Danish manufacturer or importer who has the obligation to notify the Product Registry, but foreign companies have the option of making the notification on behalf of the Danish company, for example if they wish to keep the exact composition of the product confidential.
The foreign company must provide the CVR number of the Danish importer in the notification, as the Danish company is legally responsible for the notification and must therefore confirm the import.
It is the foreign company that must update the submitted information.
A foreign company has the same option of notifying a raw material if it is included in a product that another company imports or produces.