中文内容由 Google Cloud Translation 自动生成，仅供参考；请以英文原文为准。问答资料来自欧盟化学品管理局（ECHA）官方网站。
答案（中文）
REACH法规第23(1)(a)和(b)条中“根据67/548/EEC指令归类为[...]”的措辞既指附件一中列出的物质及其统一分类，也指自行分类的物质。根据67/548/EEC指令第4条和第6条可以推断，物质应（由制造商/进口商）根据该指令附件六中的标准进行分类。此外，该指令附件一还包含经专家组讨论后由委员会分类的物质清单。由于该指令涵盖两种情况，因此，物质不仅应在附件一中与其协调分类一起列出时，而且只要符合该指令附件六中规定的分类标准（即，如果物质尚未列入附件一，则由注册人自行分类），也应被视为根据67/548指令进行分类。这两种情况都应被视为“根据67/548/EEC指令进行分类”。这种解释符合REACH法规的本质精神，尤其是REACH第23条规定的期限的目的和目标。对具有高度关注特性的物质设定较早的注册期限，旨在尽早收集有关这些物质及其用途的必要信息，并方便行业制定和推荐适当的风险管理措施。鉴于本案中具体的健康和/或环境问题，其目标并非将REACH条款的适用时间推迟数年。为此，立法机构设定较早注册截止日期的目的显然是为了涵盖这两种情况，因为在受保护的公共利益方面两者并无区别。非统一分类的物质与统一分类的物质同样存在同样的担忧。这种解释的结果是，自2010年12月1日起，一旦制造商或进口商在该日期后获得证据证明其物质符合REACH第23(1)(a)或(b)条规定的分类标准，其就有义务立即注册该物质。
Answer (EN)
The wording of Article 23(1)(a) and (b) of the REACH Regulation "classified as [...] in accordance with Directive 67/548/EEC" refers to both, substances listed in Annex I with their harmonised classification and to self-classified substances.
It may be inferred from Articles 4 and 6 of Directive 67/548/EEC that substances shall be classified (by manufacturers/importers) according to the criteria in Annex VI of that Directive. In addition, Annex I of that Directive contains the list of substances classified by the Commission, following discussions in expert groups. As the Directive covers both situations, substances should therefore be considered as classified in accordance with Directive 67/548 not only when listed with their harmonised classification in Annex I, but as soon as they meet the criteria for classification set out in Annex VI of that Directive, i.e. also when self-classified by the registrant, should the substance not (yet) be listed in Annex I. Both situations should be considered as "classification in accordance with Directive 67/548/EEC".
This interpretation is borne out by the very spirit of REACH and in particular the aim and objective of the deadlines provided for in Article 23 of REACH. The aim of the earlier deadline for registration of substances with properties of very high concern is to gather earlier the necessary information on the substances, on their uses and for industry to develop and recommend appropriate risk management measures. Given the specific health and/or environmental concerns in this case the objective was not to defer the application of the REACH provisions for further years. To this end, the aim of the legislature in setting the earlier registration deadlines was clearly to cover both cases, as there is no difference in the protected public interest. Substances with non-harmonized classification are equally a ground for the same concern as substances with harmonised classification.
A consequence of this interpretation is that, as from 1 December 2010, as soon as a manufacturer or importer obtains evidence that his substance fulfils the classification criteria set out in Art. 23(1)(a) or (b) of REACH after that date, he will be obliged to register that substance immediately.