France: Reporting Requirement for Hazardous Mixtures and Biocides

New reporting requirements took effect on January 1, 2017 for companies that export hazardous mixtures or biocides to France. The Institut National de Recherche et de Sécurité (INRS) is the recipient of the reports.

In addition to the previously required hazard notifications, the new rule mandates the following notifications:

  • Sensitization of the respiratory tract, category 1 (H334)
  • Sensitization of the skin, category 1 (H317)
  • Carcinogenicity, category 2 (H351)
  • Germ cell mutagenicity, category 2 (H341)
  • Reproductive toxicity, category 2 (H361)

Additional hazard warnings have been announced for 2019 and 2022. Reporting requirements have been in force for biocides since January 2017. Companies affected by the requirements can use the IT tool provided by the INRS: Déclaration Synapse. It requires a signature.

The background of the requirement is Article 45 of the CLP Regulation. It mandates that manufacturers, importers, and marketers report the recipe and content of hazardous chemical mixtures, biocides, detergents, and cleaning products to the national agencies that are responsible, the INRS in this case. The agencies then provide the data to poison information centers that physicians can query specifically in emergency situations. Because the reporting process differs in every country, it’s advisable for companies that do business in multiple EU countries to maintain an overview of the various requirements that apply.

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