HCPC Brands EuropeChemical Compliance Glossary & FAQ

What is REACH, and how is it different from the EU Cosmetics Regulation?

REACH regulates individual chemical substances — registration, evaluation, authorisation, and restriction — regardless of what product they end up in. The Cosmetics Regulation, by contrast, regulates finished cosmetic products. A single ingredient can therefore fall under REACH obligations even though the finished cosmetic product it's used in is separately regulated under the Cosmetics Regulation.

Does REACH require a cosmetic product to have its own Safety Data Sheet?

No. Cosmetic products are specifically exempted from the general REACH requirement to compile a Safety Data Sheet, since downstream safety communication for cosmetics is already covered by the Cosmetics Regulation's own safety report and labelling requirements instead.

What triggers a REACH registration obligation for an ingredient?

Registration is generally required once a substance is manufactured or imported in a quantity above one tonne per year. Above ten tonnes per year, the registration dossier must additionally include a Chemical Safety Report covering the substance's environmental and occupational aspects.

What is CLP, and what does it add on top of REACH?

CLP governs the classification, labelling, and packaging of hazardous substances and mixtures — determining which hazard pictograms, signal words, and hazard/precautionary statements a product must carry, based on its classified properties.

What is a Unique Formula Identifier (UFI)?

The UFI is a code required on the label of a hazardous mixture, linking that specific product to its Poison Centre Notification filing so poison centres can identify its exact composition in the event of accidental exposure.

What is Poison Centre Notification (PCN)?

PCN is the mandatory notification of hazardous mixtures to national poison centres under CLP Annex VIII, using a harmonised format, so that medical professionals can access composition information quickly in emergency situations.

Is there one single EU-wide portal for Poison Centre Notification?

Not in practice. ECHA operates a centralised submission portal, but only a limited number of member states currently accept filings through it — most notifications still need to be submitted through country-specific national systems.

What is the C&L Inventory, and who has to notify it?

The C&L Inventory is an ECHA database of substance classification and labelling information. Manufacturers and importers of hazardous substances must notify it, generally without any tonnage threshold — but downstream formulators who only use substances already classified by their suppliers typically do not have this obligation themselves.

What is an Ingredient Data Sheet, and is it the same as a Safety Data Sheet?

No — they serve different audiences. An Ingredient Data Sheet, required under the Detergents Regulation, is a public-facing list of a cleaning product's ingredients, typically published on a freely accessible website. A Safety Data Sheet is a more technical document aimed at downstream professional users and emergency responders.

Is a cleaning product still classified as a detergent if it contains no surfactants?

Yes. The legal definition of a detergent under the Detergents Regulation is based on intended cleaning or washing use, not on the presence of surfactants — so products like descaling vinegar or peroxide-based bleach cleaners are still detergents for regulatory purposes.

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