Submitting information on chemicals

Companies shall use a Chemical Notification to submit information on the chemical they have placed on the market to the authority. The notification shall be made using the online system KemiDigi. The data submitted shall be based on the safety data sheet of the chemical.
The information submitted in the Chemical Notifications is used by a variety of authorities in Finland.  There is also a public version of KemiDigi showing basic information about chemicals.
You can find instructions for using KemiDigi after logging in. Instructions for how to log in are on the home page of KemiDigi, where also video instructions are available. 

In the past, submitting information to the Finnish Poison Information Centre was possible together with the Chemical Notification, but as of 1 January 2021, it requires a separate notification. The notifications to the Finnish Poison Information Centre are made via the ECHA (European Chemicals Agency) Submission Portal, in accordance with the unified information requirements in the EU. 

Who is obliged to submit a Chemical Notification to the Chemical Products Register?

The first company with a Finnish business ID in the chemicals supply chain is obliged to submit a Chemical Notification about the chemical it has placed on the Finnish market. The notification must be made by a Finnish manufacturer or importer with a Finnish business ID. If there is more than one company importing the same chemical into Finland, each company is responsible for its own part for the import of the chemical concerned, and each of them must submit their own notification.

Companies without a Finnish business ID cannot submit a Chemical Notification to the register.

What kinds of chemicals need to be declared?

A Chemical Notification must be submitted if the chemical is classified under the CLP Regulation or if an unclassified chemical contains hazardous substances or a substance with an occupational exposure limit value set by EU legislation.  

In practice, a Chemical Notification must be submitted whenever a safety data sheet is required to be provided on a mandatory basis or upon request in accordance with Article 31 of the REACH Regulation or Appendix I to the CLP Regulation. 

A Chemical Notification must be submitted for chemicals meant for consumers. A Chemical Notification is also required for chemicals manufactured or imported for company's own use. Notifications are not required for chemicals manufactured in Finland if they are not placed in the Finnish market. 

Non-hazardous chemicals, objects or cosmetics require no Chemical Notification.

What information should a chemical notification provide?

Chemical notifications are based on sections 1, 2, 3, 9 (physical form and pH) and 14 (UN number) of chemical safety data sheets. The safety data sheets themselves are also uploaded to the KemiDigi system.

In addition to the safety data sheet information, the intended use of the mixture (EuPCS code) must also be disclosed.

The KemiDigi system can be used to draw up chemical safety data sheets that can then be saved as Chemical Notifications. In these cases, all the information required for safety data sheets must be provided as well as the disclosures needed for Chemical Notifications.

If the information on the Chemical Notification is the same, the same notification can have several different trade names.
 

Exceptions to the notification obligation

No notification is required if

  1. the chemical is used for product- and process-oriented research and development; ‘product and process orientated research and development’ means any scientific development related to product development or the further development of a chemical in the course of which pilot plant or production trials are used to develop the production process and/or to test the fields of application of the chemical'
  2. the chemical is used in scientific research and development; ‘‘scientific research and development’ means any scientific experimentation, analysis or chemical research carried out under controlled conditions' 
  3. less than 100 kg of the chemical is delivered for professional or industrial use in a year per company. 

The exception on section 3 does not apply to biocidal products, plant protection products or chemicals meant for consumer use, but they require a Chemical Notification regardless of the amount that is placed in the market. Chemicals used in regular laboratory activities require a Chemical Notification, except for under circumstances pursuant to section 3.

When should a Chemical Notification be submitted and for how long should it be in the register?

Companies must submit a Chemical Notification in KemiDigi as soon as they start to place the chemical on the market. The Chemical Notification has to be registered for as long as the company in question is placing the chemical on the market. 

Once the company ceases to place the chemical on the market, the notifier inactivates the Chemical Notification. The Chemical Notification can be inactivated immediately after the placing on the market is over (even if some retailers or users still have the chemical on the market).

When shall the Chemical Notification be updated?

If the information on the Chemical Notification changes fundamentally, the Chemical Notification must be updated. The information is considered fundamentally different if the information given in the chemical’s safety data sheet needs updating. An update is required also in other circumstances if the matter has a significant impact on the information content or the information’s registration.

These types of changes include

  1. change of the chemical’s trade name
  2. changes in the business’s details, such as its name
  3. new information relating to the chemical’s hazardous properties, classification or markings
  4. new information concerning the chemical, which may influence risk management measures

Quantitative information

Quantitative information is collected annually on all the chemicals being placed on the market on asked year, at the end of March next year. 

Quantitative information should be reported to KemiDigi on chemical, for which Chemical Notification is in accordance to legislation has been on the Chemicals Products Register within the year in question. Companies that have drawn up the notification for KemiDigi also report the quantitative information.  Businesses need to report the volume of chemicals they have manufactured or imported in tonnes as accurately as possible.

The information is used for estimating the amount of chemical substances on the Finnish market in order to establish, for example, how many tonnes of 2-propanol there were or in how many chemicals it was found in 2019. The quantitative information published in the register cannot be used to draw conclusions about the chemicals of individual businesses or the quantities of individual chemicals.

Quantitative information about substances is also available on the Nordic SPIN database (Substances in Preparations in Nordic Countries). The quantities of substances placed on the markets in Finland, Sweden, Denmark and Norway are added to the database annually from each country’s national product register.

Fees

The fees charged for processing Chemical Notifications are based on the number of notifications submitted by each business. The annual fee is

€26 per notification per year for the first 200 notifications

€13 per notification per year for any notifications after the 200th notification

Tukes charges the annual processing fees in two instalments. The invoice contains the Chemical Notifications required by law that are published at the time of the invoicing.