The guide · CLP Annex VIII
Group submissions, standard formulas and interchangeable components
Not every mixture needs a submission built entirely from first principles. Annex VIII carves out four shortcuts for specific situations — none of them available by default, all of them worth checking before you file a full individual dossier.
Group submission
A group submission lets you cover more than one mixture in a single filing, but only where every mixture in the group shares the same classification for health and physical hazards and — as the baseline rule — contains identical components at identical declared concentration ranges. The one relaxation to that last condition is where the mixtures in the group differ only in the fragrances they contain, provided the total fragrance concentration in each stays under 5%. That derogation is what makes a group submission useful in practice: one base formulation, several scent variants, filed together instead of as separate dossiers that would otherwise be identical.
Standard formulas
For a defined set of construction-sector products — cement, gypsum-based products and ready-mixed concrete — ECHA publishes standard formula datasets that a matching mixture can rely on instead of declaring its own component-by-component composition. If your product genuinely conforms to one of these published formulas, you use the dataset ECHA has already agreed with the sector rather than reconstructing the same disclosure yourself. It is not a shortcut available to construction products generally, only to the specific formula types ECHA has actually published.
The logic is the same one behind every shortcut on this page: these are product groups where thousands of near-identical formulations would otherwise generate thousands of near-identical dossiers, each one adding filing work without adding anything a poison centre did not already know from the last one. A published standard formula turns that repetition into a single reference dataset the whole sector can point to.
Fuels
A defined list of fuels gets its own exception from the standard composition rules: rather than the full component disclosure that applies elsewhere, these may be reported according to what the safety data sheet already contains, together with any other components that happen to be known. It exists for the same reason the industrial-use limited submission does — a fuel's composition is often already well characterised through other regulatory channels, so requiring it to be reconstructed a second time for the PCN dossier adds paperwork without adding information a poison centre would actually use.
Interchangeable component groups (ICG)
An ICG is a defined group of components that can be substituted for one another in a formulation without changing the mixture's classification, its hazards, or the emergency response information built around it. It is built for exactly the situation a formulator runs into when a raw material is dual- or multi-sourced and the precise substance, or its exact share, is not always known at the point a batch ships — rather than treating every supplier switch as a fresh composition change requiring its own update, a correctly set-up ICG absorbs that variability inside the group.
Which shortcut applies to you
These four routes are not exclusive of each other, and most mixtures use none of them — the standard individual submission, built with correctly declared ranges, is the right answer for most products and usually simpler than trying to force a fit that is not really there. If your product is a genuine cement, gypsum or ready-mixed concrete formula, or one of the listed fuels, check the standard formula or fuel route first, since it removes work rather than just simplifying it. A dual-sourced raw material is the clearest signal an ICG is worth setting up, and a single base formulation sold under several fragrance variants is the clearest case for a group submission.
The risk worth naming plainly: forcing a mixture into one of these routes when it does not genuinely qualify does not simplify anything, it just produces a dossier that fails validation, or worse, one that passes and describes the product incorrectly. Confirm the conditions actually hold — the same classification, the same components at the same ranges, or a genuine match to a published formula — before building the submission around the assumption that they do.
Next step
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