January’s overview of Member States decisions in relation to implementation of Annex VIII to the CLP Regulation (Regulation (EC) No 1272/2008)

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 and those countries which are still using their local systems has changed. The latest valid version is available here.

What is new compared to the previous overview of which I last wrote here?

New countries accepting PCN from January via ECHA portal:

• Belgium
• Luxembourg (the Belgian Poison Centre is responsible for the reception of all hazardous mixture declarations placed on the Luxembourgish market)

What about fees in Belgium and Luxembourg?

In Belgium the fees for submitting PCN via ECHA portal remain the same as for the local procedure. That means 200 € for a new PCN submission.

I would like to point out an important detail – if you have already submitted your notifications via the local system and you plan to submit via the ECHA portal – you will have to pay the fee one more time, as it is “double processing” from the Belgian poison’s centre perspective.

On the other hand the local notifications remain valid even after 1. 1. 2025 (if you update them accordingly with the UFI).

Luxembourg has not specified any fees, so it remains – fee free.

The list of countries, which are not yet accepting notifications via the ECHA submission portal:

• Bulgaria
• Iceland
• Liechtenstein
• Slovakia

By now you can clearly see that the situation regarding poison centre notifications – PCNs is still not harmonized across all the Member States of EU/EEA. Therefore, in the meantime, we still need to pay attention to all the exceptions, and this review is a useful tool.

It is also becoming increasingly clear that PCN notification and implementation of the process is slower than expected (and perhaps also as planned).

Now, if you are facing specific challenges in connection with UFIs and PCNs, I am happy to help. I can help save you a lot of time and effort with finding the answers. Just send me an email at luka.rifelj@bens-consulting.eu.