(And why 99% of companies learn the hard way)
Let me tell you about one of the most preventable disasters I’ve ever witnessed.
A mid-sized chemical company — let’s call them AlchemCo — was doing well. Solid product line, reliable distribution partners, and a CEO who liked clean dashboards and tight shipping schedules.
But they made one small mistake.
They waited.
Their assumption?
“We’re a serious company. We’ve got documentation. This shouldn’t be a problem.”
Wrong.
They had labels, yes. Safety Data Sheets? Kind of. Mixture components in the right format? Not even close. And their UFI codes? Mostly incorrect or worse, unassigned. The internal team started scrambling, trying to pull data from legacy ERP systems, old Excel files, and half-remembered formulations.
Meanwhile, one of their biggest distributors — who had asked for proof of PCN compliance — was getting nervous. They’d heard stories. Customs seizures. Legal holds. Fines.
Suddenly, that tight shipping schedule started to wobble.
By the time AlchemCo called us, they were nine business days from the deadline.
Now, here’s where most people expect me to say, “Don’t worry, we fixed it.”
We didn’t.
Not all of it, at least.
We triaged the most urgent products, submitted PCNs for the fastest-moving SKUs, and sent pre-submission confirmations to distributors.
But three items were pulled from their EU line-up temporarily.
The CEO was furious. Not at us, but at himself.
“I thought this would be like a fire drill,” he said. “Turns out, the building was already burning.”
The real lesson
There is no such thing as a last-minute PCN.
Why?
Because PCN is not a form. It’s not a label. It’s a regulatory reconciliation. Your data must match across multiple systems: formulation, SDS, UFI, submission portal, and even the label. And all this takes time.
And when the deadline hits, your intentions don’t matter. Only your submission does.
That’s why the smartest companies treat PCN deadlines the way pilots treat engine checks. You don’t wait for the warning light to come on.
What I recommend
If you haven’t started your PCN process, or if you’ve started but have that “nagging doubt” feeling in your gut, act on it. Now.
It’s easier and cheaper to fix problems before the deadline than after. When the emails start coming in, and your warehouse is stuck, and your partner in France is demanding answers, it’s too late for calm.
Final thought
The best compliance doesn’t feel urgent.
That’s the point.
The companies who never have a PCN emergency don’t have better luck. They just start earlier. They make it a practice, not a panic.
If this story felt even slightly familiar, that’s your signal. Use it.
Happy to help if you want someone who’s seen it all and still enjoys solving it.
Back to posts
