Guideline for notification to the Product Registry

Which substances and materials do you have 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:

• Substances and materials that must be classified as hazardous in accordance with the CLP Regulation.
• Substances and materials included with a limit value in the Executive Order on Limit Values for Substances and Materials.
• Materials that contain 1% or more of a substance that is included with a limit value in the Executive Order on Limit Values for Substances and Materials.
• Other substances and materials, which are subject to the requirements of a safety data sheet in the REACH Regulation. 

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.

Do I have to notify the ECHA Submission portal as well as the Danish Product Registry?

There are two different sets of rules, national rules and EU rules. The rules, which deal with notification to the Product Register, are national rules, and they continue to apply even if there is an obligation to make a poison centre notification (PCN) under EU´s CLP, annex VIII.

You must therefore continue to notify products to the Product Registry in accordance with the rules that apply for it.

Products used by private consumers only, just have to be reported to the ECHA portal, unless it is a biocidal product, which often has to be notified in both registers.

Notification of biocidal products

The Danish Environmental Protection Agency is responsible for the rules regarding CLP, Annex VIII and the UFI-codes so if you have further questions about this, please contact:

E-mail: CLPHelpdesk@mst.dk

Substances and materials that do not need to be notified

You do not need to notify the following substances and materials in the Product Registry: 

• Articles such as thermometers and plastic buckets.
• Substances and materials that are only used in private households
• Substances and materials imported/manufactured in quantities of less than 100 kg per year
• Food, beverages and other products ready for consumption
• Medicinal products ready for consumption
• Animal feed
• Cosmetics
• Waste
• Substances and materials containing radioactive substances
• Medical devices to be used in direct contact with the human body provided that other legislation lays down requirements regarding the device
• Substances and materials that are manufactured or imported solely for research purposes in quantities of less than 1000 kilo, for use by only a few individuals
• Substances and materials that are only in transit in Denmark
• Pesticides

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):

• Iron oxide
• Kaolin, respirable
• Silicic acid, SiO₂, amorphous
• Silicic acid, SiO₂, amorphous, respirable
• Titanium dioxide
• Substances and materials that are only subject to the unspecified limit values for organic dust and mineral dust (see the Executive Order on Limit Values for Substances and Materials - in Danish).