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 you have less than 4 (four) months left to 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.
What should you as a duty holder do about the approaching deadline?
Now if you are wondering if you fall under “duty holder” category this will help.
If your role in the supply chain is downstream user (formulator of mixtures) or importer (buying mixtures from outside EU/EEA and placing on the market in the EU/EEA) you have direct obligation according to Annex VIII of CLP. Therefore you are the duty holder.
This of course applies only for companies, established in the EU/EEA (and Northern Ireland). If your company is established outside of EU/EEA or NI, then you might want to read this blog post.
As a duty holder, you are obliged to submit PCN to those Member States, where you are placing your products on the market. Even if you just import products but don’t sell them you still need to submit PCN to “import” Member State .
Now you know what obligations you have depending on your role.
Next step is checking your product portfolio, identify the mixtures, that require PCN and the Member States in which they are is placed on the market.
Once you have identified this, you should ask your customers, if they sell in any other Member State. That’s because you need to submit the PCN for each Member State specifically (although through the same ECHA submission portal).
Therefore, if you don’t include these Member States, your customer will have to submit their own PCN or ask you to do it and update your notification. As a good practice and help to your customers expanding their marketplace, you can include all EEA countries in the beginning when submitting the notifications.
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 by 1. 1. 2025 contact us today (info@bens-consulting.eu), while there is still time.
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