As the date January 1, 2025, approaches, there has been an increase in calls, emails, and inquiries from customers regarding the submission of PCN notifications.
Today, I am writing about the most common mistakes, myths, and questions related to PCN notifications. Additionally, I will share our tips, guidance, and recommendations; I believe this will help you in your work.
Let's look at the 5 most common PCN challenges.
1. "Can I submit a PCN notification for my products without disclosing the composition?"
No.
One of the key conditions for a successful PCN notification is that at least 70% to 90% of the total composition of your product is known.
If you notify a composition between 70% and 90%, the notification will be successful with a warning to provide a more precise composition.
If you report a composition below 70%, the PCN notification will certainly be rejected.
2. "Can I use the same UFI as the manufacturer if the manufacturer hasn't arranged a PCN notification for the desired country?"
Yes, you can.
Manufacturers/suppliers often complete PCN notifications only for major markets. In this case, you can consult with the manufacturer/supplier to arrange a PCN notification for your desired country/-ies.
In the case of a negative response, you must handle the PCN notification yourself. You can use an existing UFI code provided by the manufacturer/supplier. However, we must warn you that this will reveal your supplier. Using a UFI-decoder, it is possible to identify which company created the UFI code.
3. "How long does a PCN notification take?"
This is a very relative question – let's look at 3 most common scenarios we encounter:
- Scenario 1: The Safety Data Sheet is maintained in the Chemius database and already contains all the necessary data for the PCN notification.
In this case, we open an account on the ECHA web portal on your behalf and request a connection between Chemius and the ECHA portal. Then we complete the PCN notification. This is the fastest and most effective scenario.
Based on our experience, it takes a maximum of 2 working days to obtain an ECHA account for your company. - Scenario 2: The Safety Data Sheet is not in the Chemius database.
Similar to the previous scenario, we open an account on the ECHA web portal on your behalf. Then we ask you for all the necessary data and wait for your response or the manufacturer's/supplier's response.
Be aware that during this time, we cannot proceed with the PCN notification. Once you provide all the necessary data, we convert it into the PCN notification format and send it to ECHA for review.
This scenario is more time-consuming but can proceed relatively quickly with good preparation from you and the manufacturer/supplier (based on our experience: takes between 3-5 working days). - Scenario 3: You are unfamiliar with PCN notifications and don't know where to start.
In this case, we guide you through the entire process, from obtaining and reviewing the compliance of the Safety Data Sheet to potential communication with the manufacturer/supplier, designating the legally responsible person, setting up an account on the ECHA web portal, and obtaining all the necessary data for a successful PCN notification.
This scenario is the most time-consuming, as we also need to familiarize ourselves with your needs and products (based on our experience: more than 7 working days).
4. "I added the UFI code to the Safety Data Sheet and the label. Do I need to do anything else?"
The UFI code alone without a PCN notification means nothing. A PCN notification cannot be done without a UFI code. Such a case is also called an ''empty'' UFI code.
The term ''empty'' UFI code refers to a code for which no PCN notification has been submitted, meaning the mandatory reporting of hazardous mixture properties to poison centers has not been done. This is actually one of the most common mistakes we see daily.
5. "How can I check if a PCN notification has already been done for a product?"
Unfortunately, there is currently no publicly accessible tool or other means to check the validity of PCN notifications.
Ask the manufacturer/supplier for a certificate of validity for PCN notification. The certificate should include a screenshot of the PCN notification, product name, UFI code, and recipient countries.
If you have any other questions not covered above, you can send them to spela.hudobivnik@bens-consulting.eu, and I will assist you to the best of my ability.
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