Trade Name Annex report

In the Chemical Gazette May 2018 we confirmed the removal of all the products listed in the Trade Name Annex (TNA) and the addition of 12 industrial chemicals to the non-confidential section of the Inventory.

This report outlines our TNA activity including consultation, information we received and the background to the TNA.

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The Australian Inventory of Chemical Substances (the Inventory) according to the Industrial Chemicals (Notification and Assessment) Act 1989 (the Act) should be a list of individual chemical substances, not products that are a mixture of chemical substances.

The TNA of the Inventory was created in 1992 as a temporary measure and included 2526 products listed by trade name and a general product description.

Read more about the background of the TNA

We needed composition information about products listed on the TNA. We started a consultation process with industry associations in late 2016 about the best way to get this information.

Following this consultation, in our March 2017 Chemical Gazette, we published a notice requesting composition information on the products listed on the TNA from any Australian entity. We gave industry 12 months to submit the information, with a closing date of 9 March 2018. Businesses were given the choice of providing information on the composition of the products in the TNA online or in writing.

As well as the Gazette Notice we emailed business registrants to advise them of the TNA notice. In addition, 3 reminder Gazette notices were published.

By the March 2018 deadline:

  • 23 companies provided composition information on 88 TNA listed products
  • of all the chemicals reported, 12 chemicals were not on the Inventory
  • there were no confidential listing applications

After the March 2018 deadline, all TNA products were removed and the 12 chemicals not already on the Inventory were added.

Outcomes of the TNA activity

During the 12 month consultation period from March 2017 to March 2018:

  • We received 161 enquiries via email and about 40 enquiries by phone.
  • Out of the 2526 products on the TNA, information was reported for 131 products.
  • 23 companies submitted composition information on 88 products on the TNA totalling 807 chemicals. However, some of these chemicals were reported multiple times in different products. Two hundred and seventy five (275) unique chemicals were reported. Table 1 indicates the total number of TNA products’ composition information received.
  • 3 companies identified 43 TNA products that were obsolete or no longer in production or being marketed in Australia. They confirmed that all substances contained in the products were listed on the Inventory. No composition information was provided for these products.

12 of the 275 chemicals submitted were not on the Inventory and were added under section 20AB of the Act. We conducted a preliminary search of databases to identify if any of the 12 chemicals were hazardous. We were able to ascertain that 4 of the 12 chemicals were considered hazardous, 4 chemicals were not listed in ECHA C&L Inventory database and no hazard classification could be identified from other sources for 4 chemicals. A list of chemicals that were not listed in the Inventory including information on hazard classification and labelling is given in Table 2.

In addition, 3 of the 275 chemicals were not listed on the Inventory:

  • 2 of these occur naturally in their unprocessed state and are therefore deemed to be on the Inventory
  • 1 chemical is a hydrate and its anhydrous form is listed on the Inventory. Hydrates need not be listed on the Inventory as the Act regards them as mixtures of water and the anhydrous substance.
  • Table 3 shows the chemicals that are considered to be on the Inventory, although not listed on the Inventory.

Number of TNA products with composition information

Table 1 - Number of TNA products with composition information
Number of companies reported products with composition information Number of products with composition information Number of unique chemicals reported Number of chemicals not listed on the Inventory
23 88 275 12

Chemicals added to the Inventory

Table 2 - Chemicals added to the Inventory from TNA activity
CAS Number CAS Name Molecular Formula Hazard classification according to ECHA CLP1
68130-31-4Oxirane, 2-(chloromethyl)-, polymer with alpha-hydro-omega-hydroxypoly[oxy(methyl-1,2-ethanediyl)], 2-propenoate((C3H6O)nH2O.C3H5ClO)x.xC3H4O2No information
128819-84-11,3-Propanediol, 2-ethyl-2-(hydroxymethyl)-, polymer with 2-(chloromethyl)oxirane, 2-propenoate(C6H14O3.C3H5ClO)x.xC3H4O2Harmful to aquatic life with long lasting effects, causes skin irritation and may cause an allergic skin reaction.
26125-61-11,4-Benzenedicarbonyl dichloride, polymer with 1,4-benzenediamine(C8H4Cl2O2.C6H8N2)xNo hazards have been classified.
25765-47-31,3-Benzenedicarbonyl dichloride, polymer with 1,3-benzenediamine(C8H4Cl2O2.C6H8N2)xNo information
121888-68-4Quaternary ammonium compounds, benzyl(hydrogenated tallow alkyl)dimethyl, stearates, salts with bentoniteC18H36O2.Na. Unspecified. UnspecifiedNo hazards have been classified.
214495-33-7Phenol, 4,4'-(1-methylethylidene)bis-, polymer with N1-(2-aminoethyl)-1,2-ethanediamine, 2-(chloromethyl)oxirane and 2-[[4-(1,1-dimethylethyl)phenoxy]methyl]oxirane(C15H16O2.C13H18O2.C4H13N3.C3H5ClO)xNo information
179796-73-71,2-Ethanediamine, N1,N1'-[1,7-heptanediylbis[(4,5-dihydro-1H-imidazole-2,1-diyl)-2,1-ethanediyl]]bis-C21H44N8Harmful if swallowed, causes serious eye irritation, harmful if inhaled, causes skin irritation and may cause an allergic skin reaction.
53563-70-5Poly(oxy-1,2-ethanediyl), alpha-(carboxymethyl)-omega-(octyloxy)-(C2H4O)nC10H20O3Causes serious eye damage and skin irritation.
2035064-87-8Siloxanes and Silicones, di-Me, reaction products with chlorotrimethylsilane, iso-Pr alc., silica and sodium silicate UnspecifiedNo information
121888-67-3Quaternary ammonium compounds, benzylbis(hydrogenated tallow alkyl)methyl, bis(hydrogenated tallow alkyl)dimethylammonium salts with hectorite

Unspecified. Unspecified. Unspecified

No hazards have been classified.
18765-38-3Silicic acid (H4SiO4), tetrakis(2-butoxyethyl) esterC24H52O8SiCauses serious eye irritation, causes skin irritation and may cause respiratory irritation.
67701-02-4Fatty acids, C14-18UnspecifiedNo hazards have been classified.

1 According to the classification notified by companies to the European Chemicals Agency (ECHA) under Classification, Labelling and Packaging (CLP) regulations.

Chemicals not listed but considered to be on the Inventory

Table 3 - Chemicals not listed but considered to be on the Inventory
CAS NumberCAS NameMolecular FormulaComments
10028-15-6OzoneO3

Naturally occurring

Deemed to be on the Inventory

1318-59-8Chlorite-group mineralUnspecified

Naturally occurring

Deemed to be on the Inventory

10213-79-3Silicic acid (H2SiO3), disodium salt, pentahydrateH2O Si.5H2O.2Na

The anhydrous form CAS RN 6834-92-0 “Silicic acid (H2SiO3), sodium salt (1:2)” is on the Inventory)

Hydrates are not listed on the Inventory as the Act regards them as mixtures of water and the anhydrous substance.

Background to the TNA

The Inventory is a legal device to distinguish existing chemicals from new chemicals. The Inventory lists chemicals by their Chemical Abstracts Service names and numbers (CAS) and molecular formulas.

The Inventory was developed over 4 phases from the late 1970s until 1990. In the later stages some companies were unable to get information from their suppliers on the individual ingredients in some products. To complete and publish the Inventory some businesses were allowed to nominate trade names.

To be eligible, the business had to show they were unable to get the chemical details for a product from their supplier(s), through no fault of their own.

This led to the creation of the TNA, first published in 1992, as volume 2 of the public Inventory. The TNA contained 2526 products listed by their trade names and a general product description. The TNA was to be an interim measure to give nominators time to identify the chemicals in their products. However, companies did not provide the chemical details of products listed on the TNA.

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Last update 13 August 2018