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 like this:
Since you are a GB-based company (company, established in Great Britain - England, Scotland, Wales), you are considered as a non-EU/EEA-based supplier.
Unfortunately, only companies based in the EU/EEA or in Northern Ireland can submit Poison Centre Notification (PCN) in accordance with Annex VIII of Regulation (EC) no. 1272/2008 (CLP regulation).
A non-EU/EEA-based supplier (such as your company) can only submit voluntary PCNs through a EU/EEA based legal entity (we can do that, since we are an EU-based legal entity).
In that case you get a voluntary UFI code, which you can give to your buyers in the EU/EEA and then they can do the PCN as duty holders (as importers of the mixture), referring to that UFI and must have their own UFI on the label – not the voluntary one.
This is only a means for you to protect the complete composition of the mixture. The voluntary UFI will not be legally valid if placed on the label, as your company is not a duty holder in the EU/EEA.
If you have no problem with disclosing the exact composition to your buyers, then the voluntary submission step is not needed.
In that case you only disclose what the importer needs, and they submit the PCN and inform you of their UFI code, so you can already place it on the label/packaging.
Of course, we can also submit PCNs for the importer, if you connect us with them.
Sharing information in the supply chain to be able to comply with the legislation is in our opinion crucial for a good cooperation between non-EU/EEA suppliers and EU/EEA suppliers, so in that case you could continue with the successful sales of the product.
If you need help with submitting PCNs, our team can help your company as well. Just drop us an e-mail at info@bens-consulting.eu and we will get back to you.
Photo by Rocco Dipoppa on Unsplash
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