The short answer is yes. But there’s more to that simplistic answer. Let’s take a deeper look at this case.
Now, just to make it clear, when we’re talking about the aqueous solution, we’re thinking about solution in which the solvent is water. It is mostly shown in chemical equations by appending (aq) to the relevant chemical formula.
And for suppliers of basic chemicals preparing aqueous solutions (a solution of 2 or more substances is a mixture) is a common scenario.
Let’s say you buy an aqueous solution made of a base, acid, or salt. Then you dilute it to a lower concentration and ship to you customers, as desired.
Or in some cases, you buy the pure chemical (substance) and prepare an aqueous solution of the substance, and then ship to your customer.
Either way, as soon as you prepare the solution, you fall under the category of a downstream user.
This means you have obligations according to Article 45 and Annex VIII of CLP regulation, if the final solution is also classified as hazardous to health and/or with physical hazards (with the well-known exceptions).
If the final solution is classified as hazardous to health and/or with physical hazards, then you need to notify your mixture to ECHA in those member states, where you are placing it on the market.
Examples of such mixtures can be found in Annex VI of CLP with “%” in their name. For instance, nitric acid and ammonia. Another common example of such a mixture is aqueous solution of sodium hydroxide.
The obligation of PCNs in this case may have come as a big surprise to some of you. If you need assistance with submitting PCNs for your company, write us at info@bens-consulting.eu. We’ll be happy to help you.
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