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Exporters under PIC must act now
The new submission tool for exporters, ePIC, will be launched on 2 September. All necessary data stored in the current tool, EDEXIM, will have been migrated to the new system by that date. For that migration to take place, EDEXIM users must act now. ECHA Newsletter spoke to Chiara Macchi from ECHA's Dossier Submission & PIC Unit, to discuss the changes and how they will affect companies.
Act now to ensure that your data is in ePIC
Changing from EDEXIM to ePIC is a major part of improving the submission process for export notifications and related tasks. The new system is designed to streamline the export notification processes for the benefit of industry and the designated national authorities (DNAs).
EDEXIM has been up and running for 10 years and it contains a large amount of valuable data. To be able to migrate the data to ePIC and make sure that the DNAs and industry can view their data correctly in September, PIC exporters must tag their data in their EDEXIM account using a Universally Unique Identifier (UUID). This UUID can be obtained from REACH-IT.
"Existing users of EDEXIM can log in and find more detailed instructions. Exporters must tag their data in EDEXIM by 22 August at the very latest to guarantee migration," Ms Macchi reminds. At the end of business of the same day, EDEXIM will be closed for a week and no new submissions can be made before ePIC goes live. Therefore, if companies plan any urgent exports for the end of September or the beginning of October, these need to be submitted to DNAs in advance so that they can be sent to ECHA well before 22 August. EDEXIM will be back online on 2 September but users will no longer be able to make new submissions or edit old ones – they will have read-only access to the tool until 30 November to allow them to double-check that their data was correctly migrated. If users have questions, they can contact ECHA Helpdesk.
ePIC is a step forward
ePIC was developed after extensive consultation with representatives of industry, DNAs and the European Commission. Once it was built, a number of volunteers tested it over a two-week period in April and further hands-on training was provided in May. There have also been three onsite workshops in the last twelve months to discuss the specifications of the system.
"Our aim has always been to try to make ePIC as user-friendly and easy to use as EDEXIM. This has been a challenge because we needed to add functionality to the system, and this often comes hand-in-hand with adding complexity," Ms Macchi remarks. "Our guiding principle has been that ePIC should do at least everything that EDEXIM does, but hopefully in a better way," she adds.
When ePIC is launched, we will also publish user manuals for industry users, the DNAs and the European Commission. There will be a webinar for industry users on 26 August. The programme and a registration form for the webinar are available on ECHA's website. There will also be a live session for the DNAs on 27 August.
ECHA Helpdesk will start to answer questions about ePIC from 2 September.
Easier and more efficient communications
With EDEXIM, a lot of communication to do with PIC had to happen outside of the system. Now, with ePIC, there is an embedded messaging function which allows messages to be added to a task and submitted to the next actor in the chain within the system itself. "When industry submits a notification, they can write and submit their message directly in ePIC, rather than having to notify their DNAs separately by email," Ms Macchi says and continues, "this represents a huge added value, because the processes done outside of EDEXIM were time consuming and difficult to keep track of. All the information will now be available in one place".
An improved workflow with automatically created tasks will also streamline the work. For example, some exports need the explicit consent of the importing country and ePIC improves the way that these will be managed. "Under certain circumstances, the need for explicit consent can be waived, but waiving was never included in EDEXIM. It is now available in ePIC," Ms Macchi says. "While the exporter had to submit their notifications in EDEXIM and send the request for a waiver separately, ePIC allows the waiver request to be submitted at the same time as the notification within the tool," she reiterates.
The DNAs will then receive the waiver as a task item to be completed by a set deadline in ePIC. They will then process it and forward it to the European Commission for final approval. All this is managed within the system.
Once an importing country receives a request for consent, if they do not respond within 60 days, the exporting company can submit a waiver. In EDEXIM, exporters did not know when the 60 days began. ePIC makes that clear: "Each notification in ePIC has an event history. Exporters will now be able to see the date that their DNAs have made the request for consent. This shows when the 60 days begin," Ms Macchi explains.
Reporting on exports
Each export notification is about a potential event in the future because the notifications refer to upcoming proposed exports. The PIC Regulation requires that in the first quarter of the year after the notification, each importer and exporter of PIC chemicals has to report on the actual quantities exported.
"Our stakeholders have asked for this reporting to be made possible in the new system. Although this functionality is not available in the September release of ePIC, it will happen in the first quarter of next year. Companies will then receive a task item to be completed in ePIC, which will once again facilitate and streamline the reporting," Ms Macchi states.
Earlier submission deadlines
The submission deadlines have also changed under the new rules of the regulation. Typically, three quarters of the yearly notifications have been processed in four months, starting in October each year. The upcoming peak will be the first since the new regulation has been in force.
Under the previous rules, companies could submit their notification up to 15 days before export. This obligation has now changed and they must now submit notifications no later than 35 days before the intended date of export. "We strongly encourage companies to get moving on these much sooner than they have done in previous years," Ms Macchi urges.
Interview by Paul Trouth
Top image: Fotolia
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Committee for Socio-Economic
1-4 and 8-11 June (tentative);
7-11 and 14-18 September (tentative)
Committee for Risk Assessment:
1-5 and 8-12 June;
7-11 and 14-18 September (tentative)
Member State Committee:
Biocidal Products Committee:
Management Board meeting: