Your chemicals inventory and essential EU lists: What you need to know

Whether your industry is manufacturing, healthcare, agriculture, or retail, maintaining a thorough chemicals inventory is more than just a regulatory requirement – it’s a vital component for product safety, compliance, and environmental stewardship.  

A well-managed and detailed chemicals inventory guides the direction of your business’s regulatory compliance, helping you ensure that all the chemicals you use are handled properly, adhere to safety protocols, and meet regulatory standards. However, an inventory alone doesn’t ensure compliance; keeping it up to date is crucial.  

This blog explores what makes a good chemicals inventory and guides you through the EU ‘Lists of Chemicals’ that are essential to monitor to keep your compliance efforts on track. 

What is a chemicals inventory?

Imagine a ‘tool’ that tracks every chemical substance stored, used, or produced within your facility or organization. A chemicals inventory does just that. This essential record provides detailed information on the types, quantities, and locations of chemicals, coupled with crucial safety data and handling instructions.  

Here’s a quick rundown of what a best-practice chemicals inventory should include: 

• Chemical identification data: Names, CAS numbers and chemical formulas 

• Quantity and location: The amount of chemicals present in your facility 

• Safety handling information: Usually in the form of Safety Data Sheets (SDS) 

• Tracking and usage information: Usage records detailing any inventory changes 

• Supplier contacts: All related purchase and delivery records 

• Expiration dates and storage conditions: For all your chemicals 

• Regulatory information: Data on compliance requirements for local, national, and international regulations for specific chemicals or groups of chemicals in the inventory 

Why a chemicals inventory? 

Maintaining a chemicals inventory is more than just a regulatory requirement. Knowing the contents of your chemical inventory directly influences the local regulatory obligations your business needs to comply with. 

Different chemicals and chemical groups can trigger varying levels of regulatory scrutiny, from reporting requirements to outright bans or notification requirements, while some may not even be regulated.  

Knowing the content of your inventory is therefore crucial as it determines the direction of your compliance journey, provided you know which legislation to consult and where to find it.  

The role of lists

This is where ‘Lists of Chemicals’ come in. Navigating each jurisdiction’s complex web of chemical regulations requires a keen awareness of which chemicals are regulated and how, how this impacts your business, and where this information can be found.  

Compliance with safety standards, avoiding costly penalties, and maintaining operational excellence all depend on knowing which ‘Lists of Chemicals’ relate to your inventory and business. 

Key EU ‘lists of chemicals’ to track

For any company operating in, or placing products on, the market in the EU, here are 10 significant regulations we track at Enhesa and the multiple lists you should be aware of:  

1.The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation:  

• Annex XIV on the List of substances subject to authorization  

• Annex XVII on the List of substances subject to manufacture, use and marketing restrictions and prohibitions 

2. Classification, Labeling, and Packaging (CLP) Regulation:  

• Annex VI on the List of substances subject to harmonized classification and labeling obligations 

3. Persistent Organic Pollutants (POPS) Regulation:  

• Annexes I & II: List of substances that are subject to prohibitions or restrictions on production and use 

• Annex III: List of substances subject to release reduction, minimization and elimination 

• Annex IV: List substances subject to waste management obligations 

4. Food Contact Material (FCM) Regulation:  

• Annex I: Groups of materials and articles which may be covered by specific measures 

5. Cosmetics Regulation: 

• Annex II: Prohibited substances 

• Annex III: Restricted substances 

• Annex IV: Authorized colorants 

• Annex V: Authorized preservatives 

• Annex VI: Authorized UV filters 

6. Packaging and Packaging Waste Directive: 

• Annex II: Permitted substances and materials

7. Waste Framework Directive: 

• Annex VI: Management requirements for specific waste streams 

8. Biocidal Products Regulation (BPR):

• Annex I: Approved active substances
  

9. Ozone-Depleting Substances (ODS) Regulation: 

• Annex I: Controlled substances 

• Annex III: Products and equipment containing controlled substances 

10. Fluorinated Greenhouse Gases (F-Gas) Regulation: 

• Annex I: Regulated fluorinated greenhouse gases 

• Annex II: Other regulated greenhouse gases 

• Annex III: Product and equipment market prohibitions 

Note that the legislation and related Annexes shared above aren’t exhaustive. Additional legislation may apply depending on the specific nature of your business and industry. 

Keeping up to date

In practical terms, maintaining a thorough chemicals inventory means keeping up to date with essential lists. As they’re frequently updated, it’s recommended to review lists against the substances covered in your chemicals inventory every quarter. This ensures your products and operations remain compliant with any new regulatory obligations.