Use of NONS data: is it free, or do you need an agreement?
  • Franck ThiebaultFranck Thiebault
    Regarding the notion of "legitimate owner" of data (see Article 10 of REACH) and substances covered by the Notification of New Substances Regulation (NONS). NONS are considered already registered by REACH (see Article 24) and the Technical Guidance Document on registration states that only the notifier benefits from being considered registered; any other parties manufacturing or importing the substance, but who have not notified it, must register. Thus other companies importing NONS should be considered as importers and are not exempted from the registration process.

    In the case of NONS, if we apply the CLP using EU databases, we are going to classify and label according to toxicological data that is in the NONS dossier. Is it allowed or do we need to have an agreement with the owner of the NONS dossier?
  • Steffen ErlerSteffen Erler
    Hi Frank, I'm a bit confused. CLP does not have the same rules on data use as REACH. But, if a company is an importer of a NONS substance, then that company would then need to be registered under REACH.
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