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 that this table is not entirely clear to you. So, in today’s post I decided to flip this overview around giving you information based on what this table on Page 5 is telling you.
Let us start with first column entitled “Readiness of Member State to accept notifications via ECHA submission portal”. Despite the fancy name it is basically telling you to which Member States duty holders can notify their mixtures through the ECHA portal.
Since the number of countries that are still not accepting PCN notification via ECHA portal is getting smaller every month I want to address these first. There are still 7 of them:
- Belgium
- Bulgaria
- Czech Republic
- Iceland
- Liechtenstein
- Luxemburg
- Slovakia
Now these countries above are sticking with their own systems for the time being. That means you must continue to make notifications via their national system until further notice.
All other countries (23) are already connected to the ECHA portal and you can do PCN notifications through the ECHA Submission portal. Last three countries to join in April were Malta, Romania and Spain.
Next thing you need to know is what are your submission system options (column 2 in table on Page 5). You have two possibilities here.
First one is PCN notification that are accepted only through the ECHA portal, once connection is confirmed. Here is a list of countries falling into this category - Austria, Croatia, Cyprus, Denmark, Estonia, Finland, Greece, Hungary, Iceland, Ireland, Italy, Lithuania, Malta, Netherlands, Norway, Poland, Romania, Slovakia, Slovenia, Spain and Sweden.
Second option is PCN notification accepted by ECHA portal OR national system. Here is a list of 5 countries falling into this category - Belgium, France, Germany, Latvia, Portugal.
Unfortunately, this overview is not complete as for some countries - Bulgaria, Czech Republic, Liechtenstein, Luxembourg – information is still not available.
Third thing – after countries accepting PCN notifications and options considering an appropriate submission system – is using the right language when doing PCN notifications (column 3 in table on Page 5).
Again, you have two possibilities depending on countries for which you want to do PCN notifications.
The majority of countries fall into category where you can use English OR official language of the Member State - Belgium, Croatia, Denmark, Estonia, Germany, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Portugal, Spain and Sweden.
But there also countries accepting PCN notifications only in official language of the Member State - Austria, Bulgaria, Cyprus, Czech Republic, Finland, France, Greece, Hungary, Liechtenstein, Poland, Romania, Slovakia, Slovenia.
What about the fees I hear you say?
Most of the countries (column 4 in table on Page 5) do not charge any fees for PCN notifications. These include Austria, Bulgaria, Croatia, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Iceland, Ireland, Latvia, Lithuania, Malta, Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, Sweden, Spain, Czech Republic and Romania.
Four countries – Belgium, Czech Republic, Liechtenstein, and Luxembourg – are still “under consideration” meaning that you can’t be sure if you’re obligated to pay any fees. This status tends to change in time. Last two countries for example that went from “under consideration” to “no fees” are Croatia and Spain.
There are, however, two countries where you pay fee to local authorities for doing PCN notification. These two are Hungary and Italy.
The last thing we’ll look is when you can actually proceed with placing your mixtures on the market (column 5 in table on Page 5). You also have two options.
First, you can place the mixture on the market immediately after confirmation that the dossier has passed the automatic validations of the portal. These include the following Member States – Austria, Croatia, Cyprus, Denmark, Estonia, Finland, Greece, Hungary, Iceland, Ireland, Lithuania, Malta, Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, Sweden, Romania.
Then there are countries – France, Germany, Italy, and Spain - where you have to wait for the confirmation in the submission report that the dossier has been received by the Member State appointed body.
And lastly you have countries where this piece of information is still not known – Belgium, Bulgaria, Czech Republic, Liechtenstein, and Luxembourg.
As you can see from month-to-month overview, we’re slowly moving to one PCN notification procedure and system. But you still need to be aware of differences among countries when doing your PCN notifications.
Now, if you don’t have the time or energy to do it yourselves just drop me a line and I’ll help you.
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