Yes, it is. Section 39(a) of the CLP states, “ Substances registered under Regulation (EC) No 1907/2006 ” C& at time of listing; L Range of inventory. This therefore applies to substances registered under REACH and placed on the market, regardless of whether they are harmful or not. If a substance is not classified, it should be selected in the IUCLID 6 file “ Not classified ” Option, or in REACH-IT C& Select this option when notifying the list in the online wizard.