The last relevant deadline for PCN (1 January 2025) is approaching fast – notification of mixtures that are no longer exempt under transition period after 31 December 2024.
It is September 2024. This means less than 4 (four) months left to fully comply with the Annex VIII of Regulation (EC) no. 1272/2008 (CLP regulation). If you are new to the topic, I recommend you start with some introductory reading on the topic here.
Submitting PCNs for you as distributor can be a big burden, because you often don’t get data of sufficient quality from the supply chain, especially regarding the composition of mixtures. I wrote about this here.
What should you as a distributor do about the approaching deadline?
As a distributor you should ensure the PCN is submitted for the products you distribute in all the Member States and for all the relevant trade names/UFIs.
Second thing I recommend doing is asking your supplier for confirmation in which Member States the UFI codes for the products have been notified and for which trade names.
And don’t forget, if you change the trade name/UFI of the mixture (rebranding), you also need to notify these new trade names/UFIs. It goes without saying that the same applies if you’re selling in other Member States than your supplier That’s simply because you have to submit the PCN for each Member State specifically.
Here's a quick tip for you what to do in such cases. You can just ask your supplier to include the new names/UFIs/Member States in their notification.
If they don’t want to update their PCNs or you don’t want them to know you are rebranding their products, then you will need to submit the PCNs by yourself.
All in all, after 1. 1. 2025 all relevant mixtures need to have PCN submitted before placing on the market. There is no more transition period. Furthermore, the inspection in Member States will start checking this in January 2025.
Last piece of advice – if you need PCNs successfully submitted until 1. 1. 2025 contact us today (info@bens-consulting.eu), while there is still time.
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