Record keeping for exempted introductions – chemicals that are comparable to listed chemicals

Before you read this page’s content, make sure you’ve already read and understood:

• why you must keep records
• written undertakings as records (if you’ve relied on information held by another person — such as a supplier or manufacturer — to categorise your introduction)

Go to our record-keeping overview page for this information.

Records you must keep

The type of records you must keep depends on whether you know the CAS number or the proper name (CAS, IUPAC or INCI for plant extracts under certain criteria) for your chemical. Work through the information on this page to understand your record-keeping obligations for this type of introduction.

Chemical identity

• If you know the CAS number – written or electronic record of the CAS number and either the CAS name or INCI name for the chemical.
• If you don’t know the CAS number – you must have either A or B:
  
  A. Written or electronic record of the CAS name or IUPAC name. An INCI name can only be used if the chemical and its name meet all 4 criteria:
  
  i. the chemical does not have a CAS or IUPAC name
  
  ii. the chemical is a plant extract – examples are extracts of flowers, seeds, or leaves of trees, shrubs, herbs, grasses, ferns, and mosses
  
  iii. the name of the plant extract is an INCI name based on a proper botanical name – for example, 'Helianthus Annus Leaf/Stem Extract' is acceptable but 'Sunflower extract' is not acceptable
  
  iv. the plant extract cannot be chemically modified – for example, the chemical cannot be hydrolysed, acetylated, or hydrogenated
  
  B. Written or electronic record of the names you use to refer to your chemical and a written undertaking from the supplier or manufacturer that they will give us the proper name (CAS or IUPAC) and CAS number (if assigned) if we ask for them.

Introduction requirements

If you don’t know the proper name – a written undertaking from the supplier or manufacturer confirming each of the following items. They must provide records to prove each of the following items if we ask for them.

• Records to prove your chemical:
  • isn’t listed in Annex III of the Rotterdam Convention or Part 1 of Annex A, B or C of the Stockholm Convention on POPs (unless it is introduced solely for use in research or analysis and the amount that you introduce in a registration year does not exceed 100kg)
  • isn’t listed on the Inventory with conditions of introduction or use that will be contravened.
    
    We’ll accept a signed and dated declaration that these checks took place.

• A record of the CAS name and CAS number (if assigned) for the listed chemical.
• If the terms of the Inventory listing for the listed chemical include a defined scope of assessment – records to prove that you are introducing or using your chemical in accordance with that defined scope. The information that we’ll accept depends on the defined scope of assessment.
• If the terms of the Inventory listing for the listed chemical include conditions relating to its introduction or use – records to prove you are complying with those conditions for your chemical. The information that we’ll accept depends on the conditions relating to its introduction or use.
• If the terms of the Inventory listing for the listed chemical include specific requirements to give us information – records to prove that you are meeting those requirements for your chemical. The information that we’ll accept depends on the specific requirements.