Certain EU/EEA countries mandate additional PCN notification fees, including Hungary, Italy, Ireland, and Belgium. The expenses associated with Hungary, Italy, Ireland, and Belgium are borne by the company, given that these fees are ...
Today, let's look at the third condition (c), which, unlike the first two conditions, refers to the exact concentration of the ingredient.This condition says that the exact concentration of the ingredient was submitted, but there was ...
Last time we looked at the first of the three conditions that dictate when a new UFI code must be created. Let's look at condition (b) today. In this case, a new UFI must be created, if modification of concentration of an ...
Who can import biocides into Bosnia and Herzegovina? Do you know who can be an importer of biocides in Bosnia and Herzegovina? If you don’t then this post might be for you. Now in Bosnia and Herzegovina regulations on biocides exist ...
In today's post we will take a look at all the criteria influencing the need to create a new UFI. (For easier understanding and due to the length, the post is divided into three parts – we will take a look at one of the conditions in...
Many of our clients are still struggling to connect all of the necessary data which is needed for a successful PCN notification. In this post, I'll answer the most common questions we are getting, regarding PCN notifications. 1. Do we have...
Today I'm going to write about one commonly heard myth that may cause you unnecessary worry. These days you can hear almost on daily basis that every mixture change in composition dautomatically requires a new UFI. Let me say at the ...
The European Chemicals Agency (ECHA) has prepared tons of material on UFI and PCN subject. If you have time to go down this rabbit hole you can start here. But this post is not about that. It's about getting the most content in shortest ...
PCN or PCN notification is a notification process by which a company reports information about a dangerous mixture to a single European poison center database. If this sounds familiar, that's because it's not something entirely new. Let's ...
One of the most common mistakes when using a UFI code is the appearance of a so-called "empty" UFI code. Let's see what this actually means. The UFI code is "empty" if no PCN notification has been submitted for it and / or no mandatory ...
The next relevant deadline for PCN is approaching fast – notification of mixtures for industrial use only – 1 January 2024. The only country in the EEA in which in general does not yet accept PCN notification though ...
If you haven't already, here's some basic information you need to know. The abbreviation UFI stands for Unique Formula Identifier. It is a 16-digit code that is already indicated on the labels of products that are classified as dangerous ...
To ensure a successful PCN notification, the accuracy and completeness of the information are crucial. Here's a breakdown of the data required for a successful PCN notification: # List of required information 1. Company ...
PCN notifications have generated significant buzz, especially for non-EU/EEA companies. Here are the top three crucial questions and their corresponding answers about PCN notifications. Can I be the duty holder for the PCN ...
On 25th August 2023, Commission Delegated Regulation (EU) 2023/1656 amending Regulation (EU) No 649/2012 of the European Parliament and of the Council as regards the listing of pesticides and industrial chemicals was published in ...
The transport of dangerous goods is governed by various rules and conventions, the most important of which is the ADR (Agreement concerning the International Carriage of Dangerous Goods by Road). ADR sets out strict rules for the transport...
During floods, many electric vehicles can become submerged in water. This not only affects the batteries but also the entire electrical system of such a vehicle. Today, we, as experts in the field of chemistry, address the potential issues...
Here, at Ben's Blog, we've already delved deeply into the topic of PCN notifications. Looking ahead to the latter part of 2023, it's our anticipation that PCN notifications should no longer present significant challenges. However, the ...
According to the latest analysis by Dun & Bradstreet, only 3.4% of companies in Slovenia achieve the highest, platinum excellence. BENS Consulting is among these prestigious winners this year for the fifth time in a row. The best thing...
In an industrial environment, we encounter a variety of chemicals every day that are essential for manufacturing processes. One of the important groups of chemicals that industrial and professional users deal with is diisocyanates. ...
On July 14, 2023, the European Chemicals Agency announced an amendment to Annex XVII of Regulation (EC) No. 1907/2006 concerning formaldehyde and formaldehyde releasers. The new entry under number 77 introduces restrictions and ...
You find yourself in a situation where you have prepared safety data sheets, labels, and made submissions to the National authorities and Poison Center Notification (PCN notification) for products under the new trade name. However, your ...
The deadline for harmonizing your safety data sheets in accordance with the Amendment to Regulation (EC) No. 1272/2008 (CLP) for the purposes of its adaptation to technical and scientific progress (18th ATP) expires on 1 December 2023. ...
Companies ask us constantly in which countries can we help them expand their market of biocides and of course: "How long would the registration take?". As we all know, biocides are special kind of products that require registration before ...
We get such cries for help daily. This only shows there's still a lot of confusion about UFI and PCN procedures. One of these is the language of Safety Data Sheets you need to have to do PCN notification. Let me explain. Lots of contacts ...
Before I answer the interesting question above, let's quickly repeat - the deadline for updating your safety data sheets in accordance with the Amendment to Regulation (EC) no. 1272/2008 (CLP) for the purposes of its adaptation to ...
To determine whether the received Safety Data Sheets are indeed compliant with Regulation (EU) 2020/878, you can use a few simple methods: Check if there is a reference to Regulation (EU) 2020/878 on the Safety Data Sheets, ...
If you are a chemical manufacturer in Bosnia and Herzegovina, you certainly devote a lot of time to the appearance of labels. This is certainly important if you want your product to stand out and attract customers. However, when it comes to...
We are well into the third year of the beginning (from 1. 1. 2021) of the implementation of PCN and UFI requirements according to Annex VIII to CLP Regulation. European Chemicals Agency (ECHA) has added Slovakia in this recent ...
This is not a trick question. If success matters to you, it is a deadly serious one. This true story explains why ... Yesterday a company contacted us seeking help in preparation for the tender process they want to ...
Ever had a feeling somebody is just being too smart and too attention orientated when it comes to Safety Data Sheets? After all, who even has the time to look at them? Well, here’s a true story teaching you a lot about how one ...
This news was published in the Consumer Protection Act ("Official Gazette", 236/22) and is in accordance with the decision on the introduction of a second official language from 2019. At that time, in addition to the Macedonian language, ...
The Chemical Office of the Republic of Slovenia has published news release affecting sale of already notified biocidal products: "Due to the end of the SARS-CoV-2 epidemic and the relaxation of measures to prevent its spread, the placing ...
In the last two months, I have reviewed 118 Safety Data Sheets to determine if they comply with Regulation 878/2020 or current legislation. I have found that some errors are repeated consistently - here are the 6 most common mistakes: ...
I got these two questions recently from a fellow regulatory expert: »I have found one article from you about the UFI and I wanted to re-assure two points and ask you: if the products/insecticides which are "only" classified ...
Restriction 68 of Annex XVII on perfluorocarboxylic acids containing 9 to 14 carbon atoms in the chain (C9-C14 PFCAs), their salts and C9-C14 PFCA-related substances are specified in COMMISSION REGULATION (EU) 2021/1297 – with the ...
We’re always chasing interesting questions where we can help and make life a bit easier. I found the following question on ECHA LinkedIn Group. And since not everybody is closely following these groups, I decided to share my ...
I received this question from many clients recently, so I decided this might be useful to share here on the blog as well. Here it goes: How can we as an UK-based company submit PCN to ECHA? My reply was ...
Yesterday, European Chemicals Agency (ECHA) included 9 new substances to the Candidate List of substances of very high concern (SVHC) for Authorisation under REACH. It includes for example the compound melamine, whose derivates are ...
The question above is a part of an interesting e-mail I received from a client. Today, I am going to give you some advice on what you can do in such situation. Now, let’s look at the whole email: “I have read many articles about...
The Commission expects this Act to enter into force early next year. Today, we’ll look in the details of transitional periods for adoption of the new criteria. And if you want to know what changes were made than I suggest you read ...
We still get lots of questions about the latest status of Member States decisions in relation to implementation of Annex VIII to the CLP Regulation (Regulation (EC) No 1272/2008). That's why I decided to ask ECHA for the latest update ...
Here’s how I usually describe the process of PCN notifications and UFI code creation to clients. You can steal this if it helps you. The process of PCN notifications and the use of UFI codes for chemicals in the European Union is ...
A few weeks ago, I wrote an article after the Draft CLP Revision had been published. Yesterday, European Commission adopted a Delegated Act to introduce new hazard classes under the CLP for endocrine disruptors, persistent, and mobile ...
Let me repeat what I said in my last post because it is important and worth repeating. As of January 1, 2023, all safety data sheets must be issued in accordance with the new format as determined by Regulation 878/2020. (This modifies ...
As of January 1, 2023, all safety data sheets must be issued in accordance with the new format as determined by Regulation 878/2020. (This modifies Annex II of the REACH regulation and provides legal requirements for material safety data ...
The deadline of January 1, 2023, when you must have all your safety data sheets aligned with the Regulation (EU) 2020/878, is getting closer every day. If you are confused about which legislation is the reason for these changes, then this ...
Two questions which often arise when the conversation touches new safety data sheets. Firstly, which legislation should you follow and what does each regulation demand of you? And secondly, what are the essential changes in the new safety ...
REACH Regulation (REGULATION (EC) No 1907/2006) is the basis of the chemical legislation in the EU. It set outs obligations regarding registration, authorisation and restriction obligations for products and chemicals. It also applies to ...
The General Court has annulled the Commission Regulation (EU) 2020/217 (14th ATP) in part that concerns the harmonised classification and labelling of titanium dioxide. The Courts main argument for its judgement was the fact, that the Risk...
Coolants (antifreezes) used in the automotive industry contain dangerous substances. These may include specific substances such as boric acid and borates. The presence of these substances is the reason that the sale of some coolants (...
When reviewing compliance with the ADR legislation, I note that companies that are the recipients of dangerous goods are not paying attention to the packaging in which dangerous goods are packed. According to the Dangerous Goods Transport ...
I recently received an interesting question concerning the labelling of packages containing lithium batteries: "We are currently working to find information related to the sale of LITHIUM batteries and whether there are any packaging ...
This is probably one of the most frequent question I receive regarding UFI codes. Here's another variation of such question: “Do products not classified as dangerous or that do not contain phrases with H2XX and H3XX need to have the ...
We often get interesting questions from our various clients in the chemical industry. Lately, I got one which I thought would be useful to share on this blog as well. The question was: “Is possible to get the Safety Data Sheet of a...
Last week the feedback period for comments on the upcoming CLP Revision has been closed. Now it is time for the Commission to consider the feedbacks and decide on the new rules on Classification, Labelling and Packaging of ...
European Comission has recently published Regulations regarding approvals of two active substances: Chrysanthemum cinerariaefolium, extract (CAS: 89997-63-7, EC: 289-699-3) – both types based on extraction method have been approved; ...
Today's text is important primarily for importers and manufacturers of the chemicals from the Republic of Srpska, but also for other persons who place chemicals on the market in the Republic of Srpska. The Ministry of Health and Social ...
ECHA has published on Agust 23rd a new document regarding the overview of Member States decisions in relation to implementation of Annex VIII to the CLP Regulation (Regulation (EC) No 1272/2008). You can find it here. If you follow our ...
We have new information regarding the 18th ATP. A corrigendum has been published. You can find it here: Corrigendum to Commission Delegated Regulation (EU) 2022/692 of 16 February 2022 amending, for the purposes of its adaptation to ...
If you import chemicals that are considered precursors, you are probably familiar with the special regime for importing these chemicals by now. As this is a very demanding procedure, you will be pleased with the fact that it has been ...
18th Adaptation to technical and scientific progress (18th ATP) to Regulation (EC) No 1272/2008 (CLP) has been published in the the Official Journal of the European Union on 3 May 2022: “COMMISSION DELEGATED REGULATION (EU) 2022/692...
Physical properties EUH014: »Reacts violently with water.«EUH018: »In use, may form flammable/explosive vapour air mixture.«EUH019: »May&...
I hope we can all agree these are products we all use almost unconsciously every day. But here’s a quick question for you - have you ever paid attention to the packaging in which these wipes are? Have you perhaps even gone a step ...
We often hear that Regulation (EC) No 1272/2008 ("CLP Regulation") does not apply to cosmetic products. This, of course, is true, which is most easily seen from the fact that cosmetic products do not have the characteristic pictograms we ...
As the deadline for entry into force - applicable from 1 March 2022 - is fast approaching, today I will once again provide you with some of the most important points from this regulation: Addition of the classifications of acute and ...
Now, if the subject didn’t give it away, this post is going to include a bit more technical jargon. But I can’t do otherwise - so this is a bit of a spoiler alert. Here’s a quick recapture if you’re not familiar with...
Which companies need a safety advisor for transport in Slovenia is stated in Article 28 of the Transport of Dangerous Goods Act: “Legal entities and private entrepreneurs with their registered office in the Republic of Slovenia, whose...
Companies that produce or import/carry certain chemicals into Croatia are required to keep registers on chemicals. The duty of keeping a register applies to: chemicals from Article 3 point 2 of the Chemicals Act, chemicals for which the ...
ECHA has published an updated review of Member States regarding the introduction of Annex VIII to CLP (Regulation (EC) No 1272/2008). With January’s overview the list of countries accepting notifications via the ECHA submission portal...
If you followed my blog posts then you know labelling packaging material should be mandatory in Slovenia from 1.1.2022 onward. We have now received confirmation of what has been said unofficially for some time. That is to deviate from that ...
If you sell or you are planning to sell or use biocides in Germany, then this information is crucial for your business. From January 1, 2022 a new notification procedure applies to biocides, which is set out in the German Biocide Law ...
The short answer is yes, if you have supplied the substance or mixture to them in the last 12 months. Or in other words, if it has passed more than 12 months from the last supply, you are no longer obliged to provided an updated SDS to ...
We are often asked by our clients how long they need to keep information on chemicals in Slovenia. A commonly heard answer is 10 years. Today we’ll look at this claim and see if this is simply a myth or is this information actually ...
If you sell chemicals online, then this article is something that might interest you. ECHA (European Chemicals Agency) has published a report on the results of inspections of products sold online. What were the findings of these inspections...
The European Chemicals Agency (ECHA) just published the revised guidance on efficacy of biocidal products on its web page (Guidance on the Biocidal Products Regulation, Volume II Efficacy - Assessment and Evaluation (Parts B+C), Version 4.0...
Are you still lost in biocidal products legislation jungle? Well then let me show you the way and save you lots of time, energy and of course money. In past couple of weeks we’ve recorded five essential videos – 4 of them just...
There's one thing every non-European manufacturers of has bumped into when trying to come to EU market. That obstacle is called Article 95 or »Article 95 compliance«. Here's what is says in essence: »A biocidal product ...
Today we dive into the approval procedures for biocidal products. If you've ever wondered: how to initiate the appropriate procedure, when you need to apply for a notification, national or union ...
We still get lots of questions related to the payment of local fees. These costs can, of course, have a significant impact on whether to carry out PCN notifications for these countries. So today I have another look into these fees by ...
National Poisons Information Centre (NPIC) in Dublin, Ireland, has published the national requirements regarding to poison centre notification (PCN) and the Safety Data Sheets (SDS) of these chemicals. You can find the post from NPIC here. ...
In the previous two videos, Bojan has already explained what biocidal products are and what types of products we know. Today, we are building the story of biocides forward. So let’s look at what biocidal active substances are...
Are you familiar with biocidal product types? Here’s a quick quiz – just 3 simple questions - for you to check your knowledge about biocides. First, how many biocidal product types are there and in how many groups they ...
Biocides are a challenging field. That is why we intentionally started BENS Consulting's YouTube channel with this topic. In this short 5:32 minute video youl'll find all the basics such as: What is a biocidal product anyway? How can you ...
Finally, BENS Consulting YouTube channel is live. To be precise there are two of them – English and Slovene.You’ll find here 5 min educational videos packed with: simple, powerful explanations you’ll ...
“N,N–dimethylformamide is an aprotic medium polar organic solvent classified as toxic to reproduction 1B, acute toxicant 4 (inhalation and dermal route) and as an eye irritant 2 in accordance with Regulation (EC) No 1272/2008 of...
In the first post - link here - we looked at the obligations of persons involved in the trade in chemicals in Bosnia and Herzegovina. In the second part - link here - I presented what are the requirements for specific chemicals? Today we ...
ECHA by 23. 11. 2021 has not yet published an updated review of Member States regarding the introduction of Annex VIII to CLP (Regulation (EC) No 1272/2008). In other words, in October and November there were no changes as to which ...
In the first post - link here - we looked at the obligations of persons involved in the trade in chemicals in Bosnia and Herzegovina. Today, however, is about another important area that you need to know if you don’t want to get stuck...
Bosnia and Herzegovina has a specific state system. It consists of two entities: Republika Srpska and the Federation of Bosnia and Herzegovina, and a special administrative unit – the Brčko District. Consequently, different ...
Companies ask us daily in which countries we can help them notify their biocides. So, we sat down and put together the list of countries (organized in alphabetical order) where we have already made notifications and can therefore help you...
Now, REACH registrants have a way to “reliably combine different sources of non-animal data on skin sensitisation properties of their substances”. This is achieved through usage of in ...
ECHA by 12.10. did not publish an updated review of Member States regarding the introduction of Annex VIII to CLP (Regulation (EC) No 1272/2008). In other words, in September there were no changes as to which countries accept PCN ...
I have recently received a very interesting question related to the implementation of 14th ATP, specifically labelling of mixtures containing titanium dioxide. The question was as follows: "We use titanium dioxide as a raw material for our...
Why is this important? Because now everyone can “access data from the EU’s first public database of substances of very high concern in products, SCIP”. There are two important implications of using this now public ...
ECHA has published a new document on Linkedin regarding the overview of Member States decisions in relation to implementation of Annex VIII to the CLP Regulation (Regulation (EC) No 1272/2008). This ...
New classification and labelling of titanium dioxide as a substance or in mixtures according Delegated Regulation (EU) 2020/217 (a.k.a. 14th ATP) is just around the corner – it applies from 1st October 2021. We already wrote on this ...
Thrilled to announce that BENS Consulting is broadening its franchise family. We're extremely pleased Nina Pajović is joining as a CEO and exclusive owner of Bosnia and Herzegovina franchise. So now BENS Consulting offers you local ...
Since launching Chemius in 2006 lots has changed. We built Chemius first for us as there weren't any tools like that on the market. Creating and managing chemical documentation was and still ...
In case you've missed it, CHEManager International published an article Working with Data Instead of Documents written by BENS Consulting's CEO Bojan Buinac. Here are just a couple of gems verified by real-case studies you also might be ...
We already wrote something about what the 15th ATP in general brings about a year ago, when this change was published in the Official Journal of the European Union. As the date of entry into force - applicable from 1 March 2022 - is ...
It's time for Chemius 2.0. (For those of you who are new to the subject, Chemius is a tool we build to help our clients effectively manage their chemical documentation in real time. You can read more about this service here). We've been ...
We are repeatedly asked what are the so-called ATPs to the CLP Regulation. ATP stands for "Amendment to technical progress" - to adapt the Regulation to technical and scientific progress. Here is a list arranged in chronological ...
The 14th ATP enters into force on 9 September 2021. This fundamental amendment can be summed up in two words - titanium dioxide. Let’s look at the details. The amendment applies to mixtures containing titanium dioxide (CAS No 13463-67...
When talking about ATPs (“Adaptation to Technical Progress”), we mainly refer to the updates to the harmonized list of classifications and labelling of substances in CLP from Annex VI. This CLP rule is “alive” and ...
I’ve been getting a lot of questions on SVHC and SCIP reporting in recent months. If you are new to this field, then I recommend that you start with this blog post. It will make it easier for you to ...
Here’s the July’s update (version 8.0, from July 5th, 2021) on the different positions of the Member States regarding the implementation of Annex VIII of the CLP Regulation. If you missed the April review (ECHA did not issue a ...
Recently, one of the more common questions has been related to the payment of local fees. These costs can, of course, have a significant impact on whether to carry out PCN notifications for these countries. For this purpose, I have ...
If you want to sell hazardous chemicals in the Slovenian market you must firstly obtain a license to trade in chemicals. Here are two conditions for getting that license: Your company must be registered in Slovenia (...
UFI and PCN has become a reality in 2021. As expected there are some difficulties when it comes to understanding and fulfilling these obligations. But two mistakes come out regularly when dealing with clients. Both can cost you lots of ...
17th Adaptation to technical and scientific progress (17th ATP) to Regulation (EC) No 1272/2008 (CLP) has been published in the the Official Journal of the European Union on 28 May 2021...
Underestimating the size of your company when registering substances is one of the most common mistakes we see in our work. Now, ECHA (European Chemicals Agency) has made it very clear that there could be financial consequences should they ...
Here’s the April’s update (version 7.1., from April 4th, 2021) on the different positions of the Member States regarding the implementation of Annex VIII of the CLP Regulation. I received many emails saying...
European Chemicals Agency (ECHA) added Latvia in this recent report on implementation of Annex VIII to CLP Regulation (Poison Centre Notification). Here’s the last valid list of 20 EU/EEA member states where you can submit your PCN ...
In PT1 - disinfectants for human hygiene - efficacy tests to prove the biocidal effect against bacteria and yeasts depend on the intended use. For general and professional use (outside the medical field), according to the Chemicals Office...
If you still offer the possibility of purchasing sulfuric acid separately from the product in Slovenia - e.g. electrolyte to start the battery - then you need to be aware of some imitations brought by the new Regulation. Sulfuric acid...
First, let’s take a look at how the term “custom paint" is defined. This is a paint that is formulated or produced in limited quantities. It is also custom made for the individual consumer or professional user. And finally, it ...
Let’s look at another interesting example today concerning SCIP notification. Let’s say you’re a company that manufactures articles for customers to their order. You then also sell these articles to them. These ...
This is one of the most common questions I receive daily. Therefore, in this post, I am going to provide some essential information to help you understand the process. The entire process is about successfully proving the effect of the ...
On 19th January 2021, the European Chemicals Agency (ECHA) has published 2 new entries on the candidate list for the authorization of substances of very high concern (SVHC). These new entries are the following: Right after the ...
This question might interest you. »We are going to sell chemical substance as a final product with our own trade name. Do we have to use UFI and register also this product (substance)? Chemical name of the substance and ...
European Chemicals Agency (ECHA) just added Finland in relation to implementation of Annex VIII to CLP Regulation (Poison Centre Notification). Here’s the last valid list of 19 EU/EEA member states where you can submit your PCN ...
Have you ever considered selling products under your “private label”? Here’s a situation we see often. Maybe you find it familiar too. You are thinking of selling several products under “private label”.&...
European Chemicals Agency (ECHA) just added three new countries in relation to implementation of Annex VIII to CLP Regulation (Poison Centre Notification). Here’s the last valid list of 18 EU/EEA member states where you can submit ...
European Chemicals Agency (ECHA) just added three new countries in relation to implementation of Annex VIII to CLP Regulation (Poison Centre Notification). Here’s the last valid list of 15 EU/EEA member states where you can submit ...
With 1. 1. 2021 a lot has changed regarding regulation of chemicals in the EU: Brexit has come to pass without any special agreement on chemicals – meaning the UK is now officially a third country&...
Article 95 of Regulation (EU) No 528/2012 concerning the making available on the market and use of biocidal products states that the supplier of an active substance must be on the list of active substances and suppliers (i.e. lists under ...
We find this table on page 4 very useful as it gives you so many information packed on one sheet. Currently there are 12 EU/EEA member states where you can submit your PCN notification: Austria Croatia Denmark Estonia Germany Hungary ...
Always start with the basics. Once you know the basics, it’s much easier to add new content and put it into practice. A permanent change is similar to making a snowball: make a core, then drop it down the hill and add new layers. The ...
Here is a list of countries where we help you with national notification of your biocides. It's in alphabetical order along with time frames so you can quickly see how long it usually takes for your biocidal products to get approved...
Clients often ask us about the official sources where they can look or research. So, we gathered 11 links here which we find useful. Here they are (listed in alphabetical order): European Chemicals Agency: C&L ...
These five points are golden - they're short, to the point and guarantee your labels are penalty-proof. Label elements From Article 17 of regulation (EC) No 1272/2008 of the European parliament and of the council of 16 December 2008 on ...
Rumors that European Commission or ECHA will again postpone the deadline for PCN notifications due to COVID-19 proved to be just that - rumors. European Commission just issued the final draft of Commission Delegated Regulation, amending ...
The latest article »Can we generate a new unique formula identifier (UFI code) ourselves?« has sparked quite a few responses. Therefore, today I want to clarify once again what an "empty" UFI code or "empty" UFI identifier means...
The entire question I received is actually a bit longer and reads as follows: "Can we generate the UFI ourselves (the generator is fairly simple) or do we need any further registration by country for which we would need, say, you?" Because ...
PCN notification does not end with the submission of the notification application. After the notification is successfully done, you have to keep it updated. Tracking modifications and updating notifications is just as crucial as is ...
Let us put the process in 4 steps needed for the successful PCN submission: Generate Unique Formula Identifier (= UFI) Prepare and submit the application through IUCLID Cloud Get status Success Track & manage Generate UFI&...
Although there is a lot of information about PCN and UFI out there, we still get questions that show uncertainties and an unclear understanding of differences between these two. Just the other day, we got an inquiry for the UFI code. The ...
15th Adaptation to technical and scientific progress (15th ATP) to Regulation (EC) No 1272/2008 (CLP) has been published in the the Official Journal of the European Union on 11th August 2020. It brings changes to the classification and ...
We find this table above (page 4 in document) very useful as it gives you so many information packed on one sheet. It is regularly updated by European Chemicals Agency (ECHA) and therefore relevant for anyone dealing with UFI / PCN. You ...
Today we will talk about another new development in chemical legislation, entering into force on 5 January 2021. This new development is the reporting on SVHCs in articles to the SCIP Database. SCIP is an English abbreviation for Substances...
On 25 June 2020, the European Chemicals Agency (ECHA) has published 4 new entries on the candidate list for the authorization of substances of very high concern (SVHC). This is, therefore, a change in the chemical legislation, this time on ...
You know the saying "a picture says more than a thousand words"? This saying refers to today's infographics. We tried to present all the essential information from the last article on the topic of dates for submitting information to the ...
The Article 95 of the Regulation (EU) No 528/2012 states: To put it more simply, only biocidal products containing an active substance, whose manufacturer or supplier is included in the list under the Article 95 of the Biocidal Products ...
Today we have prepared an article for you on dates for submitting information to the Poison Centre according to the type of use. (This article is based on the Guidance on harmonised information relating to emergency health response - Annex...
We received lots of replies regarding our last blog post yesterday. Among other things you were asking us if we can translate the official notice from The Slovene Chemical office. You can now read English translation of Slovene official ...
The Chemicals Office has issued a notice of changes in the approval of disinfectants, which will take effect on 1 June 2020. There are two changes. The first concerns the notification under the simplified procedure. As of 1 June, the ...
Yesterday, the Slovene Chemicals Office updated a memo relating to: extraordinary authorizations for disinfectants with biocidal products already authorized in accordance with Regulation (EU) No 528/2012 on the making available on the ...
Recently, the production of hand-cleaning preparations and various disinfectants in the form of alcoholic solutions, gels, wipes, sprays etc. has increased significantly. All of these products also need to be transported from ...
Recently, the use of hand-cleaning preparations and various disinfectants in the form of alcoholic solutions, gels, wipes, and sprays has increased significantly. These products may be subject to Regulation (EC) No 1223/2009 on cosmetic ...
Many companies ask us in which countries we can assist them in notifying biocides. Namely, the biocidal product must be notified in each country where you wish to place it on the market. Therefore, registering a product in Slovenia does not...
Yesterday the Slovene Chemicals Office announced it will issue extraordinary permits for disinfectants with approved biocidal active substances. Here the translation of that official news (link to original source). The announcement of the ...
These seven points are golden - they're short, to the point and can save your business one day. Label elements From Article 17 of regulation (EC) No 1272/2008 of the European parliament and of the council of 16 December 2008 on ...
With tactile warning and safety closure must be equipped products intended for the general public (general use), depending on the type of danger. This does not apply to aerosols designated as H222 or. H223. Tactile Warnings of ...
Clients often ask us about the official sources where they can look or research. So, we gathered 9 links here which we find useful. Here they are (listed in alphabetical order): European Chemicals Agency: C&L Inventory This...
If you missed the first post on this topic, you can read it here. Now, let’s go to the e-mail that came to us in response to this first post. Here’s a brief summary of the message: “We sell hand sanitizers and ...
The title of this article is a typical question we receive daily. So first let's look how Brexit stands and what is the legislation on chemicals? Is the procurement of chemicals in the United Kingdom already considered as imports from third...
...has started - 2 down, 10 more months to go. What are you doing about it?
Questions are always a great source of useful content. The question below is one such example: “I have to thank you for all the information we receive, which are very helpful and given in a friendly way. But I do have one question ...
Have you ever wondered if you need an ADR transport document when doing presentations of your products and therefore carrying cleaners - both in different packagings and of different types - that may represent dangerous goods for ...
I recently received another interesting question that I want to share with you (with minor modifications for better understanding). It reads as follows: “We have a product that is supposed to be classified as a medical device. ...
Why don't we look in more detail remaining two mistakes we regularly find in Safety Data Sheets? Mistake no 6: Product's labels are marketing material and separate from SDS This is a very costly mistake. The content on the label must always...
Last time we took a closer look at the first two mistakes we often see when reviewing safety Data Sheets (SDS). Let's look today the next three mistakes: Mistake no. 3: We didn't prepare the SDS so we're not responsible for it. Mistake no...
This question is very often when it comes to Slovene market and obligations towards regulatory bodies. Here's the last e-mail – and our answer that you might find interesting: »I came across your very interesting articles but I ...
I just love pictures that make things easy to understand. That's why we prepared one - hope you like and understand it too. Please let me know will you?
I would like to share with you two answers to questions related to biocides. They might come in handy for you as well. Here is the first question: “I wonder if it is necessary to notify biocidal products in Slovenia if they have ...
Chemical inspectors have begun to conduct inspections of hazardous chemicals sold on the World Wide Web. They are mainly monitoring the sales of consumer goods and professional products available in private companies' online stores ...
There are 7 mistakes you don't know you could be making when it comes to Safety Data Sheets. I suspect anyone interested in Safety Data Sheets - or better results - may find this breakdown interesting. Here are the first two mistakes (...
On 16 January 2020, there was a new change in chemical legislation, this time at European level. The European Chemicals Agency has published 4 new entries on the candidate list for the authorization of substances of very high concern (SVHC...
A few days ago, we were contacted by a Swiss company (therefore company is based outside the EU). They wanted to know if BENS Consulting could generate UFI codes for them in our own name? Our answer was unfortunately NO, BENS ...
This article is important for all, who are exporting substances/products into the Eurasian region - Russia, Belarus, Armenia, Kazakhstan and Kyrgyzstan. There are considerable changes coming to the EAEU-REACH area, and the deadlines for ...
The European Commission has adopted a delegated Regulation amending the CLP Regulation (1272/2008), which postpones the first compliance date for reporting (UFI and PCN) to Poison Centres, for mixtures intended for consumer use, from 1. 1. ...
Let's have a look today at the third condition (c), which – as opposed to the first two – pertains to the exact concentration of an ingredient.This condition states that an exact ingredient concentration has been submitted, ...
Previously we had a look at the first of the three conditions based on which a new UFI must be created. Let's have a look at condition (b) today. In this case, a new UFI must be created, if modification of concentration of an ingredient ...
In today's post we will take a look at all the criteria influencing the need to create a new UFI. (For easier understanding and due to the length, the post is divided into three parts – we will take a look at one of the conditions in ...
Today I decided to explain in a single post the meaning of the UFI, PCN and PCN file. That’s because I have noticed that the aforementioned acronyms have been widely used recently. However, most users do not know what these acronyms ...
These days you can hear almost on daily basis that every mixture change in composition demands new UFI. This general truth is simply not true. While it’s true that UFI has narrowed some of the composition ranges of substances used ...
Up until the moment I was writing this post, it still seemed that the United Kingdom will exit the EU on 31 October 2019 – with or without the agreement. What does this mean for all of you who are importing substances or mixtures from...
I would like to share another question related to storing hazardous chemicals in Slovenia. "We are arranging the final details at the chemical warehouse. We need an absorbent for some products that are categorised in storage class 3. Can ...
Here's another question regarding ADR transport which might interest you: »Which papers do we need to give to ADR drivers that we order for transport of our goods? »We usually give instructions for drivers in our ...
I'm sitting in a meeting room with three people from a well-known distinguished company. They are explaining how they handle chemical documentation. One of them is in charge of obtaining, storing and printing Safety Data Sheets. The other ...
Clients often ask us about the offical sources where they can look or reserach. So we gathered 8 links here which we find useful. Here they are (listed in alphabetical order): European Chemicals Agency: C&L Inventory This ...
One of the major advantages we offer our clients involves quick and verified information they need. I would like to share an e-mail from a client preparing to sell chemicals online. The client has the following doubts: "Before we launch ...
Do you know the saying that history is life's teacher (Historia, magistra vitae)? The current situation involving the UFI code and PCN notification, which will enter into force in January 2020, shows that we are not very good students. To ...
In 2019, Platinum Credit Excellence represents only 1.2% of the Slovenian market. This is an above-average rating among companies that have been showing Golden AAA's credit rating for three consecutive years. BENS Consulting is among the ...
As of 1 September 2019 the new Rules on Product Classification, Packaging and Labelling (Pravilnik o klasifikaciji, pakovanju i obeležavanju proizvoda) CLP/GHS 105/13 and 52/17 shall enter into force. The change is intended to harmonise ...
As of 1 January 2020, new requirements regarding sending information and labelling hazardous mixtures for consumer usage will enter into force on the EU level. We are talking about the UFI labelling and the regulation of PCN notifications. ...
Would you like to know which requirements you have to fulfil if you generate waste? What are your obligations and what has changed in the field of waste packaging? What is an extended manufacturer accountability and how to manage ...
By now you have probably been familiarised with the fact that appropriately prepared safety sheets are a valuable source of information. They contain comprehensive data about substances or mixtures, which are used to prepare the measures ...
Recently, the ADR has become a relatively important area in Slovenia, because fines (and not merely warnings) immediately follow the found irregularities. This can cost companies a lot of money, along with lost time and reputation. At our ...
Lots of times details are decisive when it comes to chemical legislation. Here's a simple case regarding essential oils that happened earlier this week. Let's start with an e-mail I received ... "I am struggling to get the...
Recently, we have witnessed another example clearly showing how important and valuable details are. The Austrian police controlled dangerous goods transport. While reviewing documentation they found that a driver did not have the ...
Traffic police and traffic inspectors in Slovenia are checking if the cargo, transported by your drivers, is secured against movement. Quite recently, a driver carrying dangerous goods in limited quantities (small packaging units) was ...
What elements must a label include? Are there any rules you must take into consideration when it comes to their application? I apologize if these two questions seem obvious to you, but we get them so often I decided to write a short email ...
Here are 7 things I suspect anyone interested in Safety Data Sheets - or better results - may find helpful. Information contained in the Safety Data Sheets (SDS) is confidential. Absolutely not. This is still one of the top false &...
As of 1 July 2019 a new transport document format will have to be used for the transport of small quantities of dangerous goods as per section 1.1.3.6 of ADR (to 1000 points). ADR 2019 determines: "In the case of intended ...
The response to our post about labels was surprising and positive at the same time. We have received many requests to prepare a similar list of the most frequent mistakes for safety data sheets or SDSs in short. Below, you can find the list...
Methanol is a frequent element used in liquids for windshield cleaning or defrosting (CAS 67-56-1, EC 200-659-6), and it will be subject to certain restrictions in the near future. As of 9 May 2019, the REACH Regulation 1906/2007 (Annex ...
What is a biocidal product? How can I determine if a product is a biocide or cosmetics product? What are legal obligations when it comes to biocides? What is the difference between authorization and notification of biocidal product during ...
There's tons of sales-slaughters, but here's 7 frighteningly common ones that involve SDSs: Safety data sheets which don't get done properly – let alone are continuously updated. Updates of SDSs take ages costing you time, energy and...
I would like to share with you my presentation, which I held at the last BENS event in November 2018. In it I have gathered the most important information about labelling and packaging of hazardous chemicals. I hope you find it useful...
Doing a good job makes clients happy. And communicating with them – also providing information that is not always sales related – shows you care. So, here’s a list of seven common mistakes virtually everyone makes when it ...
Today's post is related to one of the most common questions I get: “How can I quickly check if SDSs we get are any good?” To be honest, for more years I care to admit we have tried to determine what makes a good SDS. Not based ...
Laundry washing capsules are liquid household detergents kept in single-use soluble packaging, because when in contact with water the capsules dissolve. They can be purchased at almost any household cleaning agents shop department. They ...
Two weeks ago, we published the first article in the series of articles regarding new developments in chemical legislation; i.e. related to the UFI code. I soon received many responses in connection to this subject to my e-mail address. As ...
Years ago, I worked for a very successful consulting company. We worked crazy hours. The pressure was tremendous. We were just cogs delivering results in the shortest time possible. I still remember the blackboard where ...
I heard my father often say. I couldn’t quite understand it at the time. But I now more and more realize how right he was. I often come out of meetings, where people are nodding, even cheering for a solution that would help them ...
Today, we're starting a series of short blogs about a novelty that will be introduced gradually, but it will enter into force on 1 January 2020 for consumer chemicals. This is a novelty in the field of hazardous mixtures labelling. We have ...
This is the second part of the article, where I'm busting the myths about safety data sheets (SDS) and labels, which many believe are true. However, they are simply not. Here are the first three myths from Part 1: #1: Only inspectors read ...
Here are the 7 myths about safety data sheets (SDSs) and labels, which I frequently hear and which are considered to be true. However, they are not. Since there are too many myths for one article, let me share today with you the first 3 (...
Recently, I have received 6 questions about safety data sheets. Since the answers are quite extensive, I would like to share with you the first three of them. And the next three will be answered in a couple of days ... When does a ...
According to the Bisnode financial analyses for 2018, BENS Consulting belongs to the top 5.7% of the best business entities in Slovenia. In other words, credit rating excellence was reached only by 9,773 companies out of the 171,786 ...
I just returned from two business meetings. What caught my attention is their different stories on how they approach clients. You must be thinking what does that have to do with safety data sheets? As you'll see more than you think. Both ...
Any company that wants to sell HAZARDOUS chemicals in the Slovenian market must obtain a licence to trade in chemicals. The licence may be obtained if the company meets the following conditions: It must be registered in Slovenia (...
On February 1, 2018, the 8th amendment to CLP Regulation no. 1272/2008 entered into force. It sets forth that by the end of the transition period - January 31, 2020 - all safety data sheets and labels must be updated with the new H and P ...
According to the Bisnode financial analyses for 2017, BENS Consulting belongs to the top 6.8% of the best business entities in Slovenia. In other words, credit rating excellence was reached only by 11,440 companies out of the 167,703 ...
The significance of detail during ADR transports is evident from the following story. A company was transporting goods – dangerous as well as non-dangerous goods according to the ADR – using a transport vehicle that could only ...
The safety data sheet is a chemical’s identity card. This means that the safety data sheet includes all information related to the chemical: basic information about the chemical (name, code, supplier), chemical composition, ...
This is one of the most common questions in my everyday conversations. There is a simple way to make sure, whether your product is dangerous goods for transport. Document that will help you is the safety data sheet (SDS). In the section &...
One of the most common error is not to provide consistency of the safety data sheet and label contents. This is also one of the first elements that an inspector will verify. He or she will simply take or ask for a product, review the label ...
The answer is written in the Guidance on the compilation of safety data sheets (SDS): “In all cases, suppliers of a substance or a mixture which requires a safety data sheet have the responsibility for its contents, even though they ...
Last month, company A from Ljubljana (capital city of Slovenia), which sells special cleaning agents, received a smaller order from Ptuj. The company does not have its own vans or field sales specialists; therefore, they outsourced the ...
Basically, it applies that all information, regardless of the origin of the safety data sheet (SDS), is written in the document in accordance with the legislation. However, the form or manner of quoting information can vary depending on the...
What happens when concealment during the transport of hazardous goods (ADR) does not pay off, can be demonstrated by the following example. To evade payment of ADR transport fees, a company hid the goods to be transported abroad in ...
Primarily, this depends on your intentions and goals. In fact, you can conceal them but you cannot hide them. Based on our many years of experience, I can assure you that your competition has all of your Safety Data Sheets. This is a fact. ...
We often come across the myth that some information contained in the Safety Data Sheets (SDS) is confidential. A basic rule applies. No confidentiality may be imposed on information that should be included in the Safety Data Sheet. Only one...
For whom is the Safety Data Sheet (SDS) intended? Why do we prepare it? Does it have to be prepared? First, let’s have a look at what the guidelines say on this subject: SDS must provide comprehensive information on a substance or ...
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