Article 45 and Annex VIII to CLP stipulate that all economic operators who place mixtures constituting health or physical hazards on the market in the EU, including Norway, Iceland and Liechtenstein, are obliged to submit a Poison Centre Notification. By definition, "placing on the market[...] means supplying or making available, whether in return for payment or free of charge, to a third party. Import shall be deemed to be placing on the market" (Article 3 (12) REACH). Accordingly, the manufacture as well as the import of and trade with mixtures are considered as placing on the market. While notifications have ...