As the compliance date for Poison Centre Notifications is only four months away, we decided to answer your most pressing questions about the new requirements.

What is PCN?

Regulation (EU) 2017/542 harmonises the requirements for poison centre notifications (PCN) for EU member states and EEA countries Iceland and Norway. It amends the CLP regulation (EC) 1272/2008 and introduces the new annex VIII. Find out more about the requirements that need to be addressed in the context of PCN according to CLP Article 45 / annex VIII on our PCN Service page.

The challenges experienced by organisations preparing for the new harmonised mode of PCN can be highly individual, depending on business areas, models and needs – for example with respect to confidential business information. Our experienced chemical regulatory team can help you address these challenges – contact us here to make an enquiry.

What is the difference between deadline and ‘compliance date’?

1 Jan 2021 is the compliance date, as the notification requirements according to Annex VIII of CLP start applying then for new mixtures for consumer use. It is not a deadline; mixtures notified with the current system don’t need to be re-notified until 2025.

What are the penalties for non-compliance?

Enforcement is a responsibility of the Member states – please contact the relevant one for more information.

How does Brexit affect my PCNs?

After the transition period, the UK will be a 3rd country. Consequently, the obligation to notify falls on the importer in the EU country on the first compliance date for poison centre notifications: 1 Jan 2021.

Will there be a postponement of the compliance date?

German chemical industry body VCI, among others has confirmed that it supports a call by the Federation of German Industries (BDI) for the postponement of most key chemical regulatory compliance dates, including PCNs and SCIP, due to the pandemic. However, no decision about postponing has been made so far.