Voluntary Poison Centre Notification (PCN) can be a useful tool for ensuring compliance, but its benefits—and challenges—depend on whether you’re an importer or a manufacturer. Let’s break down the pros and cons for each group.
You can read my first blog post of this Voluntary submission series here.
For non-EU manufacturers: A way to support compliance
Many non-EU manufacturers struggle with Poison Centre Notification because they are not legally allowed to submit a mandatory PCN themselves. A voluntary PCN offers a workaround.
Benefits for manufacturers:
✅ Protects confidential formulas – Instead of sharing full formulations with each importer, manufacturers can submit a voluntary PCN and provide importers with the necessary UFI.
✅ Ensures consistency across multiple markets – A voluntary PCN helps standardize compliance for products sold in multiple EU countries, reducing the risk of inconsistent reporting.
✅ Simplifies compliance for EU partners – By providing a UFI linked to a voluntary PCN, manufacturers make it easier for importers to handle regulatory obligations.
Challenges for manufacturers:
❌ Does not replace importers’ obligations – Even with a voluntary PCN, importers must still complete their own submissions.
❌ Cannot be used for labelling – The UFI generated from a voluntary PCN cannot appear on product packaging; only an importer’s legally required UFI can.
❌ Additional costs – Manufacturers pay for voluntary PCN submissions without replacing the need for importers to file their own.
For EU importers: A helpful but incomplete solution
For importers, voluntary PCN can be a double-edged sword. While it provides valuable compliance support, it does not eliminate their regulatory duties.
Benefits for importers:
✅ Simplifies data collection – Instead of gathering full composition details, importers can use the UFI from the voluntary PCN in their submissions.
✅ Reduces compliance workload – Some of the notification burden shifts to the manufacturer, streamlining the process.
✅ Protects trade relationships – Importers can continue selling products without demanding full formula disclosure from non-EU suppliers.
Challenges for importers:
❌ Still responsible for PCN compliance – Even with a voluntary PCN, importers must submit their own mandatory PCN to national authorities.
❌ Cannot use the voluntary UFI on labels – They still need to generate and apply their own UFI for compliance.
❌ Potential delays – If manufacturers delay voluntary PCN submissions, importers could face setbacks in their own compliance process.
Final thoughts:
Should You Use Voluntary PCN? For non-EU manufacturers, voluntary PCN is an excellent way to protect formulas and help importers comply. For importers, it offers convenience but does not remove their legal obligations. Understanding these dynamics is key to making the right compliance decisions.
In the next post, we’ll explore why a Voluntary UFI alone isn’t enough for compliance—and how to avoid the biggest pitfalls.
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