Understanding the European chemical inventories and their significance in the EU REACH regulatory framework.
The European Union maintains three primary chemical inventories that form the backbone of its chemical regulatory framework. These inventories—EINECS, ELINCS, and NLP—are crucial for determining the regulatory status of substances in the EU market, particularly under the REACH regulation.
These inventories serve as the foundation for identifying "phase-in" or "existing" substances that were eligible for extended registration deadlines under REACH, as opposed to "non-phase-in" substances that required immediate registration before being manufactured or imported into the EU.
Important: As of April 2025, the last REACH registration deadline of May 31, 2018, has passed. All substances manufactured or imported into the EU in quantities of one tonne or more per year must now be registered, regardless of their status in these inventories.
The EC (European Commission) Inventory is a comprehensive database that combines the three independent chemical inventories: EINECS, ELINCS, and NLP. Each substance in the EC Inventory is assigned a unique EC number that serves as an identifier in the European regulatory context.
EC numbers follow a specific format based on the inventory to which they belong:
| EINECS Numbers | Format: 2XX-XXX-X or 3XX-XXX-X Example: 200-001-8 (Formaldehyde) |
| ELINCS Numbers | Format: 4XX-XXX-X Example: 400-010-9 (Mixture of: 4-[[bis-(4-fluorophenyl)methylsilyl]methyl]-4H-1,2,4-triazole; 1-[[bis-(4-fluorophenyl)methylsilyl]methyl]-1H-1,2,4-triazole) |
| NLP Numbers | Format: 5XX-XXX-X Example: 500-002-6 (Reaction product of: phenol-formaldehyde-rosin glycerol ester) |
| List Numbers | Format: 6XX-XXX-X, 7XX-XXX-X, or 8XX-XXX-X These are provisional numbers assigned to substances that were pre-registered without an EC number |
Note: List numbers (starting with 6, 7, or 8) should not be used in Safety Data Sheets (SDS) as they do not have the same legal status as official EC numbers.
Regulatory Significance: The EC number is a key identifier in regulatory documentation, including Safety Data Sheets, REACH registration dossiers, and Classification and Labelling notifications under CLP (Classification, Labelling and Packaging) Regulation.
EINECS is the foundational chemical inventory of the European Union, established to identify substances that were deemed to be on the European Community market between January 1, 1971, and September 18, 1981.
EINECS was developed through a comprehensive process:
EINECS was officially published in the Official Journal of the European Communities C 146A on June 15, 1990, and includes approximately 100,000 substances.
Each substance in EINECS is identified by:
Under the REACH regulation, substances listed in EINECS were considered "phase-in" substances, which meant they were eligible for extended registration deadlines based on their tonnage band and hazard classification:
To benefit from these extended deadlines, companies needed to pre-register their substances between June 1 and December 1, 2008, or submit a late pre-registration under specific conditions.
ELINCS contains substances that were notified and placed on the European market after September 18, 1981, under the previous chemicals notification scheme established by Directive 67/548/EEC (the Dangerous Substances Directive).
ELINCS was established in support of Directive 92/32/EEC, the 7th amendment to Directive 67/548/EEC. It includes all substances that were notified under the Notification of New Substances (NONS) scheme until May 31, 2008, when REACH fully replaced the previous notification system.
The final edition of ELINCS, published in 2009, contains 5,292 substances in total. Each substance in ELINCS is identified by:
Unlike EINECS, which was a static inventory, ELINCS was regularly updated as new substances were notified under the NONS scheme.
Under REACH, substances listed in ELINCS were also considered "phase-in" substances, making them eligible for the same extended registration deadlines as EINECS substances if they were pre-registered.
Importantly, notifications made under Directive 67/548/EEC were considered as registrations under REACH, with the following provisions:
NONS notifications were automatically transferred to the REACH-IT system, and notifiers received REACH registration numbers to replace their NONS notification numbers.
The No-Longer Polymers (NLP) list includes substances that were considered polymers under the reporting rules for EINECS but were no longer considered polymers after the definition of a polymer was changed in 1992 by Council Directive 92/32/EEC, the 7th amendment to Directive 67/548/EEC.
The NLP list was established to address a regulatory gap created by the change in polymer definition. It includes substances that were:
The NLP list is non-exhaustive, meaning it does not include all substances that might qualify as no-longer polymers. Each substance in the NLP list is identified by:
The NLP list mainly consists of the following groups of substances:
| Alkoxylated Substances | Substances that have undergone alkoxylation (addition of alkoxy groups), such as ethoxylated alcohols or propoxylated amines |
| Oligomeric Reaction Products | Products of oligomerization reactions involving multiple monomers |
| Oligomers from One Monomer | Short-chain polymers consisting of a small number of monomer units of the same type |
| Dimers and Trimers | Substances consisting of two or three monomer units |
| Polymer-like Substances | Substances containing 50% or more by weight of species with the same molecular weight |
Under REACH, NLP substances were treated as "phase-in" substances, similar to those in EINECS and ELINCS, and were eligible for extended registration deadlines if pre-registered.
During the pre-registration phase of REACH, approximately 40,000 substances were pre-registered without an EC number. To facilitate the formation of Substance Information Exchange Forums (SIEFs) and other REACH processes, ECHA assigned provisional list numbers to these substances.
List numbers follow these formats:
Important: List numbers do not have the same legal status as official EC numbers and should not be used in Safety Data Sheets. They are provisional identifiers used primarily for REACH-IT administrative purposes.
When a substance with a list number is registered under REACH, ECHA may assign an official EC number if appropriate, or the substance may retain its list number in the REACH registration database.
The European Chemicals Agency (ECHA) now maintains the EC Inventory, which includes EINECS, ELINCS, and the NLP list. This inventory is publicly accessible and searchable through ECHA's website.
The EC Inventory published by ECHA is a copy received from the Joint Research Centre (JRC) in 2008 when ECHA was founded. As of April 2025, the database contains 106,212 unique substances/entries.
Users can search the EC Inventory by:
The EC Inventory can be accessed through ECHA's website, which provides both search functionality and the option to download the complete inventory.
Note: The European Chemical Substances Information System (ESIS), previously maintained by the European Chemicals Bureau (ECB) at http://esis.jrc.ec.europa.eu/, has been discontinued. All relevant information has been transferred to ECHA's information systems.
In addition to the EC Inventory, ECHA maintains a database of substances registered under REACH. This database provides information on: