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 country, considering the data available at the moment.
For the time being local fees related to PCN procedures are still being charged by four countries:
- Hungary – price of € 50 per product;
- Italy - annual fee of € 50 per local distributor (regardless of the number of products)
- Belgium – € 200 per product although you can't do PCN notifications via ECHA Submission portal
- Ireland – annual fee of € 650 per company (or € 200 if notifying less than 10 products) for the use of poisons centre's emergency number.
You can read more about Ireland's decision here.
What's important to know is that this list is not final. In fact there are three countries - the Czech Republic, Liechtenstein and Luxembourg – which have not yet defined their situation, meaning that they may introduce fees. If these are the countries you sell in, it may be sensible to submit PCN notifications at a later date, when this information becomes known.
(Here's a link to last valid review of Member States regarding the introduction of Annex VIII to CLP (Regulation (EC) No 1272/2008)).
Let's now quickly go though the countries that do not charge fees for PCN notifications. These include Austria, Bulgaria, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Greece, Croatia, Iceland, Latvia, Lithuania, Malta, Germany, the Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, Sweden, Spain, and Romania.
All this only confirms what you already know. PCN procedures are still not harmonized across all the Member States of EU/EEA. You need time, patience and dedication to take all these changes into account and do the work properly.
Now, if you are short on time or facing your specific challenges in connection with UFIs and PCNs, we are happy to help. We can help save you a lot of time and effort. All you need to do is contact me.