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UFI / PCN | June 8, 2020

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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 VIII to CLP).

The dates for submitting information to the Poison Centre (hereinafter referred to as PCN reporting) will take effect gradually.

Importers and downstream users (manufacturers of mixtures) who place on the market mixtures that have not yet been notified in accordance with national legislation in each EU country will be required to carry out PCN reporting in accordance with the following dates:

  • for mixtures for consumer use: from 1 January 2021;
  • for mixtures for professional use: from 1 January 2021;
  • for mixtures for industrial use: from 1 January 2024.

The cut-off date is therefore determined according to the type of use of the mixture, i.e. consumer, professional or industrial use. Let's take a quick look at what these terms actually mean:

  • Mixture for consumer use means a mixture intended for use by consumers (e.g. "Paints for artists, craftsmen and amateur creators", see figure below).
  • Mixture for professional use means a mixture intended for use by professional users, but not in industrial areas (e.g. "Decorative paints", see figure below).
  • Mixture for industrial use means a mixture that should only be used in industrial areas (e.g. "Automotive coatings", see figure below).

Below is an example of how you can determine the date for PCN reporting based on the type of use.

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Figure: Identification of information requirements and expiry date by type of use; source: Guidance on harmonised information relating to emergency health response - Annex VIII to CLP, page 33

Finally, let's look at a case study.

Formulator 1 produces a fragrance. It is sold to an industrial user (formulator 2), who uses this fragrance in the production of a detergent intended for the general user. What are the dates for PCN reporting?

In this case, it should be borne in mind that now the original mixture (fragrance) is also intended for consumer use. The type of use is based on the end user. This means that the deadline for PCN reporting for both formulators is 1 January 2021. Formulator 1 must carry out PCN reporting for the fragrance after this date, and Formulator 2 for the detergent.

This is just one of the cases that may occur. If you have a different challenge, share it with us and we will help you solve it.

Disclaimer:
Information on this blog is prepared with utmost care, but it is not about (chemical) consulting, and the provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can write to us at bojan.dimic@bens-consulting.com

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