Time's Up: Did You Submit Your Mixture to the European Chemicals Agency before the Deadline?

On Bens's Blog, we have extensively discussed the importance and requirements of PCN notifications.

Now, that the deadline for PCN was January 1, 2024, it is crucial to understand the consequences of using unreported chemical mixtures and how to avoid potential issues. Let's explore some key questions and answers on this timely topic.

1. What happens if you haven't arranged PCN notification for chemical mixtures by January 1, 2024?

Unnotified mixtures can no longer circulate legally in the market. Selling these mixtures after the PCN notification deadline poses a risk of sanctions and penalties. Therefore, importers and downstream users must promptly engage in PCN notification and comply with legal requirements.

2. Who is obligated to perform PCN notifications?

Duty holders as defined in Article 45 of Regulation CLP No. 1272/2008 include importers and downstream users placing hazardous mixtures on the market.

Alternatively, a "third-party user" can prepare a dossier in the IUCLID system. A third-party user, authorized by you, is a company with a confirmed user account by the European Chemicals Agency (ECHA).

Read more about duty holders and the challenges they face here.

3. Which mixtures need to be notified?

Mixtures classified as hazardous to health (H3xx) and/or physical hazards (H2xx) according to Regulation (EC) No. 1272/2008 ("CLP Regulation").

Non-hazardous products or those only classified with H4xx do not require PCN and UFI.

Additionally, information on mixtures classified solely as gases under pressure (H280, H281) or explosives (H200, H201, H202, H203, H204, H205) is not necessary.

For products that are substances, not mixtures, PCN and UFI are not required.

4. What are the most common errors in notification?

Among the most common mistakes in PCN notification is solely marking with a UFI code without completing the PCN notification. Such a UFI code is empty – learn what an empty UFI code means here.

5. How can Bens Consulting assist you?

Dealing with the complexity of PCN notifications and preventing potential errors requires expert assistance. Our team of professionals at Bens Consulting is here to help you successfully meet the requirements. For a quick and effective solution, contact me at spela.hudobivnik@bens-consulting.eu.

In the coming weeks, we will continue to provide detailed advice and guidelines on addressing the challenges of PCN notifications and why timely action is crucial for your business. Stay tuned to Bens Blog, where we bring you the latest information and advice from the world of industrial chemicals.