CLP Article 45 Workshop for SAP Customers supported by VCI

With the support of the German Chemical Industry Association (VCI), opesus AG offers a workshop on CLP Article 45 (Poison Centre Notifications, PCN) for SAP customers.

Date and Time


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Date and Time: 7th of February 2019, 9:30 – 16:30


Lindner Hotel & Sports Academy Frankfurt

Otto-Fleck-Schneise 8

60528 Frankfurt/Main


Optional Evening Event: Pre-workshop social

Date and Time: 6th of February 2019, 6 pm

Location: In the conference hotel

Dresscode: Casual or Smart Casual


This event is targeted toward SAP customers and specifically VCI members that are obliged to submit notifications according to CLP Article 45 (Poison Centre Notifications – PCN). They will get practical advice on how to deal with the challenges ahead:

  • Get advice and best practice tips from industry leaders and SAP experts to meet your regulatory requirements
  • Collaborate and learn more about your obligations as well as available guidelines and tools
  • Benefit from our experience with ongoing pilot implementations and the ECHA pilot project for the PCN format 
  • Get ready for the first submission deadline on the 1st of January 2020 for mixtures intended for consumer uses

To learn more about the regulation, visit ECHA at

We expect around 60 participants.

The conference language is English.


  • Regulatory requirements of CLP Article 45
  • Guidelines, tools, and expectations from ECHA
  • Software from SAP and opesus
  • Industry challenges and best practices


  • Authorities
    • European Chemicals Agency (ECHA)
    • Bundesinstitut für Risikobewertung (BfR)
  • Industry
    • BASF
    • Biesterfeld
  • IT experts
    • SAP
    • opesus


09:30Alexander WegeneropesusGreetings and opening
09:50Daniel SompolskiECHAPoison Centres Notifications as of 2020
10:35Dr. Herbert DeselBfRNational implementation of CLP Article 45 in Germany
11:30Ralf CoenningSAPSAP and CLP Article 45. Now and with S/4HANA.
12:05Marvin BahnsenopesusStatus and timeline for opesus EPN
13:25Michael SteigerBiesterfeldChallenges of Poison Centre Notifications from a chemical distributors point of view
14:00Dr. Jörg SpankeBASFChallenges and recommendations from a chemical producer
14:55Markus PogrzebaopesusBest practices and recommendations for implementing CLP Article 45
15:40PanelPanelPanel discussion
16:20Alexander WegeneropesusSummary and farewell

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Event Information


The registration fee is 390 €.


Several rooms have been reserved from the 6th to the 7th of February 2019. The rate is 119,- € and includes breakfast and VAT. You can make the reservation during registration. Or you can contact us under You can pay for the room directly in the hotel.

About opesus

Since 2013, we at opesus have been dealing with product notifications to poison centres. Our opesus EHS Product Notification is the market leading solution for SAP EHS customers to submit such notifications.


  • Is an active participant in the ECHA IT User Group for CLP Article 45. An overview of all participants can be found on the ECHA website.
  • Participates together and on behalf of the VCI in the ECHA pilot project for the PCN format.
  • Works with the national authorities.
  • Is represented in various SAP EHS user groups, particulary the VCI group for SAP EHS.
  • Coordinates regularly with product management and development teams of SAP.


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Implications of PCN-Format of CLP Article 45 for Product Notifications

The European Chemicals Agency (ECHA) has published the technical format for reports to poison centres (according to CLP Article 45)! The new PCN-Format is based on the internationally harmonised IUCLID format. This article explores the effects the new format will have on industry.

IUCLID format for product notifications

Contrary to the preliminary draft, the new PCN-Format is now based on the IUCLID format. The IUCLID software allows data on chemical properties to be maintained, stored and exchanged. The internationally harmonised IUCLID format is used for this purpose. This format will now also be used for notifications to poison centres in accordance with CLP Article 45.

The IUCLID format consists of a variety of templates for documents, which are structured according to the type of information it contains (e.g. GHS data).

For the PCN format, 15 existing documents are reused. In addition, two new templates are added to the IUCLID format: “Product Information” and “Dossier Header”, which provides notification type details (e.g. update). All completed documents are combined into a dossier, which associates the contained documents through administrative data. The completed dossier will subsequently be sent to the national authorities. The dossier can then be used by national poison centres for emergency calls.

Effects of the PCN-Format for the industry

At opesus, we work in close cooperation with industry, ECHA and SAP to assist companies with their CLP Article 45. We are currently developing a new version of our software opesus EHS Product Notification, which supports the new PCN-Format. Based on our experience, we see the following effects of the new format:

Increased Complexity

A dossier consists of many documents that are linked by administrative data. The new PCN-Format is therefore very complex and much more comprehensive compared to previous formats.

For example, a very simple notification (a few substances with no “special” types) generates about 1,500 lines of XML code in PCN-Format. In comparison, the notification of the same mixture in the previous German (BfR) format consists of about 150 lines of XML code.

Possible use of IUCLID software

One way to create IUCLID-compatible dossiers is to use the IUCLID software. The software is available for free. However, the data must be maintained manually via the input mask of the software. For this reason, in our opinion the use of IUCLID software is advisable only for smaller companies with very limited mixtures subject to notification.

Note: In the past, SAP EH&S had an IUCLID interface. However, the interface currently only supports the older IUCLID 5.4 version and will be discontinued in SAP S/4HANA. From our point of view therefore, the IUCLID interface in SAP EH&S is not a viable solution.

Annual IUCLID updates

The IUCLID format is subject to annual updates. These updates can be prompted by changes in legislation or to the PCN-format. Also, changes that do not originate from CLP Art. 45 need to be evaluated and may cause adaptions to PCN notifications. For all solutions that creates notifications in PCN-Format, availability of software maintenance is therefore essential to be able to react to changes in time and reliably. We recommend maintenance for all our customers for our opesus EHS Product Notification software.

Nordic Product Registers

Future of Nordic Product Registers in context of CLP Art. 45

The Nordic Product Registers are among the most extensive chemical product registers in the world in terms of required information as well as quantity of registered products and substances. Well over 2,000 companies are obliged to report to the national authorities annually.  Recent developments regarding legislation and the use of technology raise the question about the future of the Nordic Product Registers. Read more

ECHA releases draft of European XML-format for product notification

In April 2016 ECHA released a preliminary draft of the European XML-format on harmonised product notification. The format is supposed to standardise the variety of formats and possibilities of product notification within the EU and to ease the situation of importers and producers of chemicals, biocides, cosmetics and detergents.

A first assessment of the draft:

Overview of the required tasks

  • Administrative data: Version of reporting format, reporting EU-member state, date and time of transmission
  • Information about the reporting company: company name, address, telephone number, E-Mail address and VAT
  • Contact information: name and telephone number for fast access on product information, name and number of the manufacturer of the product and name and number of the know how carrier of the formulation.
  • Information on mixture: aggregate condition, colour, relevance of pH value and pH value, Unique Formula Identifier (UFI), toxicological data, GHS classification, GHS labelling and the composition
  • Composition: composition is distinguished between substances, mixtures of substances and generic components. The concentration, be it exact or approximate, must be defined for all components. Furthermore, the classification of all components is to be stated. Substances need to be identified by their chemical name, CAS, EC and index number. Mixtures are to be specified by name, UFI and company data. Fragrances and colorants can be specified as generic components.
  • Product details: Several products can be reported per formula. There must be stated: trade name, intended use (one to three options – end consumer, industrial, professional), product category as defined by new categorization and information about package size and packaging type. It is also possible to state any identifiers of the product such as product number, EAN-Code, etc as further identifiers. As an option, safety data sheets for each product and language can be transferred as attachment of the notification.

Comparison to the BfR-format, currently used in Germany

Compared to the XML-Format of the Federal Institute for risk assessment (BfR, Bundesamt für Risikobewertung), which already electronically transfers product notifications in Germany, the required indications are very similar.  Following differences can be mentioned:

Unique Formula Identifier (UFI)

Mixtures will include an UFI Code that links them to their ingredients. This code must be displayed at the product label. The UFI changes with the wording. Companies create this code with an UFI generator. The UFI Code solves the problem of an (unknown) mixture within a composition. It is not necessary to know the exact composition of the mixture of the supplier of the notification. The UFI of the mixture is sufficient. In contrary, the BfR-format requires the exact composition.

One mixture – many products

The EU-format data model permits notification on several products regarding the same mixture. This resembles very closely the common data models and suits the SAP EHSM data model very well. In the standard data model, mixture corresponds to real substance and products correspond to the materials assigned.  Das Gemisch entspricht im Standarddatenmodell dem Realstoff, die Produkte den zugeordneten Materialien. With BfR-format, the product name is leading. This is why information about mixture is reported repeatedly for products of the mixture when the product names vary.

Company identification

Identification of the company is based on value added tax ID. The Federal institute of risk assessment (BfR) identifies producers or placing on the market by BfR-company code.

Categorisation of products

The new system for product categorisation, which is expected to be available end of 2017, allows the EU to identify a statistical analysis of incidents possibly needing risk minimization measures. The product classification complies with use categories of BfR-Format.

Further information on harmonisation:

No central data base

Notifications must be submitted to national authorities since there will be no central European database.


The language used will be the official language of the reporting country or, if accepted, English.

Existing notifications remain valid

Existing notifications remain valid until 2025 in so far as there are no significant changes in composition.

Time schedule

The EU-format has been published as preliminary draft in April 2016. The realization of the appropriate CLP regulations and the publication of the final format are planned for the years 2016 and 2017. Also, the provision of the UFI generator and the new product categorisation system is to be expected until end of 2017.

Solution for all customers of SAP EHS Management

opesus EHS Product Notification (EPN) will support the upcoming EU XML and represents a comfortable and reliable way to allow customers of SAP EHS Management fulfil their reporting obligations. EPN is the preferred software solution of  SAP EHS Management customers for reporting notifications in Germany and Switzerland.

Link Poison Centers: