How to submit a voluntary PCN without losing your mind

If you’ve decided a voluntary PCN makes sense for your business, great.

Now comes the question everyone asks next.

How do we actually do it?

Here’s the full process. No fluff. No guessing. 

Step 1: Decide if a voluntary PCN is the right fit

Ask yourself:

• Are you a non-EU manufacturer trying to support your EU customers?
• Do you want to protect your formula while staying compliant?
• Are your importers capable of doing their part?

If the answer is yes, then keep going. 

Step 2: Collect the required data

You’ll need:

• The full formulation
• Toxicological data
• Classification and labelling info (under CLP rules)
• Product identifiers like trade name and packaging types
• Intended use: is it for consumers, professionals, or industry?

This is your foundation. Don’t skip it. 

Step 3: Find a legal EU-based entity to submit for you

You cannot submit this yourself if you are outside the EU or EEA. But a partner like BENS Consulting can submit it on your behalf.

That legal presence is not optional. It is required.

Step 4: Generate yourvoluntary UFIs

Your EU-based partner will handle this for you. 

Step 5: Create the PCN dossier

Use the ECHA Cloud Services or a specialized tool like Chemius.

Your dossier should include:

• The UFI
• All the product details you gathered in Step 2
• A list of the countries you want to notify
• The submitting legal entity

Get it all in there. No gaps. 

Step 6: Submit via the ECHA Portal

Once the dossier is ready, upload it to the system.

You’ll get a confirmation of receipt. That means the Poison Centres now have the info.

This step can also be handled through Chemius if you’re using it. 

Step 7: Inform your importers and partners

Tell them what you’ve done.

Share the UFIs. Explain how it helps. Remind them they still need to do their part.

A voluntary PCN does not replace their obligations. It supports them. 

Step 8: Keep it up to date

Formulation changes. New customers. New countries. Regulation tweaks.

Any of those can trigger the need to update your submission or prepare new ones.

Track changes and act early. Don’t let your compliance age out quietly in the background. 

Final thought

Submitting a voluntary PCN is not difficult. But it does take precision and planning.

If you want to protect your formula and support your importers, it’s worth doing right.

In the next article, we’ll look at the choice between EEA-wide and country-specific PCNs. You’ll see which one fits your business best.