Who can join ?
DetNet is open to all companies placing detergent or cleaning products on the market and responsible for classification and labelling for skin and eye effects under CLP in the EU plus other European countries with national CLP implementation:
- whether multinationals or small and medium-sized enterprises
- whether members or non-members of A.I.S.E. or its National Associations;
- whether manufacturer, retailer or importer (agent).
Which products are covered ?
The priority products for which DetNet is available are laundry detergents (liquids, powders), hand dish wash detergents and all-purpose cleaners (non-extreme pH products), both consumer and professional products.
DetNet could also be used to classify other product types with similar chemistry (i.e. those based on surfactants for example carwash products).
Other product types may be added to the DetNet database in future.
How much does it cost?
The DetNet fees comprise an 'annual subscription fee' (variable according to annual turnover band of the company for products within scope) and a 'classification logging fee' linked to the number of mixtures successfully classified using DetNet reference formulations.
How do I join ?
- Fill in and submit the online subscription application form.
- Nominate your classification expert.
- Sign user agreement.
- Pay subscription fee.
Which are the elements ensuring the DetNet website security and data confidentiality?
The website security is paramount, therefore all measures have been taken to ensure high level of security, such as:
- the members area website is https://
- there is a EV-SSL certificate for the website
- company’s specific ingredients are only seen by experts from that company i.e. not visible to other companies or even to the DetNet Manager.
- no company formulation details are stored on the website (all formulation details are deleted when the expert logs off the system).
When can I start using it ?
Apply and sign user agreement as of 27 November 2013.
Tool operational for use: from 6th of January 2014.
Which non-EU European countries have implemented (or about to implement) CLP in their national legislation?
EFTA countries (Iceland, Liechtenstein, Norway and Switzerland), Turkey and Serbia have implemented (or about to implement) a version of CLP in their national legislation.
How to determine the DetNet subscription fee annual turnover band if my company supplies detergent and cleaning products in a European country but not in the EU or EFTA or Turkey?
The company should select the relevant turnover band based on the most recent annual turnover for products in scope in the European country of supply.
Can Consultancies (i.e. not supplying/manufacturing Industry + cleaning products but offering classification service to Industry + cleaning products companies) be members of the DetNet?
Such Consultancies cannot be DetNet members in their own right but one or more of their consultants may be retained by a member company who nominates them as their Classification Experts. The Classification Expert can only access the DetNet database to classify that company's formulations.
Can a company manufacturing ingredients for detergents and cleaning products apply for DetNet?
A company manufacturing ingredients for detergents and cleaning products cannot apply for DetNet. DetNet covers only classification of detergent and cleaning products mixtures, not individual substances.
Can retailers subscribe to DetNet?
A retailer can subscribe to DetNet if the following conditions are met:
- The retailer places detergent or cleaning products on the market AND
- the retailer is responsible for classification and labelling for skin and eye effects under CLP in the EU plus other European countries with national CLP implementation.
Can a company access the DetNet database before subscribing to DetNet (i.e. submit online subscription form, nominate expert, sign user agreement and NDA)?
For confidentiality reasons the database cannot be accessed before joining DetNet and before all contractual arrangements are completed. It should be kept in mind that annual fees have been set to a fairly low level for these reasons and that companies will mostly pay for ‘successful classifications’.
How long will it take to receive the access details to the DetNet database from the moment a company starts the subscription procedure?
If the company signs and sends the required documentation, and pays the subscription fee quickly, it could take more or less 10 working days from the day the subscription form is submitted online to the day the access password is sent to the expert(s).
If a company completes the DetNet subscription process, but cannot use any of the reference formulations from the database, can the company unsubscribe and recover the annual membership fee?
In this case the company would not be able to recover the annual membership fee but still has the option of contacting A.I.S.E. regarding possible in vitro testing of the formulation to be classified, and subsequent addition of the test data to the DetNet database.
It has to be noted that in this case A.I.S.E. funds the testing, the company would retain ownership of the formulation (formally releasing it as a Reference Formulation in the database) but A.I.S.E. would own the test data - the company would not be eligible for data compensation in this instance. If the company subsequently uses the data for classification purposes, they would not pay Classification Logging Fees.
Is a company subscribing to DetNet required to have a classification expert?
When subscribing to DetNet, each company has to nominate one or more classification experts. The access to the database will be allowed for the expert, providing he/she complies with pre-defined eligibility criteria. In case a company does not have in-house expertise, the company can use the services of independent consultants (list available on DetNet website).
In the case where several experts working in the same department want to use the DetNet database, can all of them have access with the same membership?
The access to the DetNet database is assigned on an individual basis, i.e. each expert nominated by a company who meets the eligibility criteria will receive a login and password. In the case several experts want access to the database, each of them will have to submit the expert nomination form and the non-disclosure agreement in order to receive him/her personal access details.
What is the process for the case-by-case assessment of experts that do not meet the eligibility criteria?
In case a nominated expert does not meet the eligibility criteria, e.g. somebody with no university degree, detailed information on his work experience related to Classification & Labelling will be reviewed (e.g. experience in assigning classification to detergents and how long, experience in discussing classification decisions with authorities). If needed, the Scientific Advisory Panel will be consulted and asked for recommendation on whether the person is eligible or not. The assessment could take about 10 working days.