The transition period for the new PCN requirements has now ended. As of January 1, 2025, the requirements in Annex VIII of CLP fully apply to all hazardous mixtures. This means that correct PCN registration for affected products must be in place with ECHA.
ECHA will be conducting an enforcement project during the first half of 2025, aimed at ensuring correct PCN registration exists for affected chemical products. They are also checking whether labeling and safety data sheets for the products are correct and contain relevant information.
In short, all chemical products classified as hazardous must have a so-called UFI code and PCN registration. Simply put, most products marked with hazard pictograms (warning symbols) are covered.
The basic rule is that whoever has the best knowledge of the product’s composition should do the PCN registration, but exactly which role in the chain has that responsibility can vary case by case. However, everyone who places a chemical product on a market has the obligation to ensure that PCN registration is completed.
Since January 2021, all poison information is submitted directly to ECHA through their web tool. There is quite a bit of information that must be in place, not least you need to know the exact content of the product to be registered.
You must complete PCN registration before the product is placed on the market for the first time. You also need to make a new notification if the product changes based on certain criteria.
The threshold to get started with PCN submissions may feel daunting, but it doesn’t have to be impossible to overcome. With the right guidance and help, you will become more effective and stay clear of the most obvious pitfalls.
We assist a broad range of clients with various aspects of their toxicological information. We are involved in the entire process, from analysis of existing information and advice to the very practical steps of actually submitting PCNs to ECHA. Often, our work will also result in us providing targeted training for relevant personnel. We can be there for you too, every step of the way.