PCN notifications have generated significant buzz, especially for non-EU/EEA companies. Here are the top three crucial questions and their corresponding answers about PCN notifications.
Can I be the duty holder for the PCN notification, if my company is located outside EU/EEA?
If your customer’s company is located outside of EU/EEA, then you cannot be the duty holder. Duty holder is the legal entity located in the EU/EEA.
Hiding the composition is important for our company. How can we be compliant without showing our hand?
A non-EU/EEA-based supplier (such as your company) can only submit voluntary PCNs through an 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.
What if I don’t mind showing the compositions of our products?
If you are comfortable with disclosing the exact composition of your mixture to your buyers, then the voluntary submission step becomes unnecessary.
In this scenario, you would only need to provide the necessary information to the importer, who will proceed with the PCN submission and share their assigned UFI code with you. You can then incorporate this code onto your product labels or packaging.
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