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New guidelines to improve your export notifications
ECHA is publishing guidelines for EU-based companies that export hazardous chemicals to countries outside the EU under the Prior Informed Consent (PIC) Regulation, to help them improve the quality of their export notifications.
These guidelines specifically focus on prohibited and allowed uses of exported substances in the EU, which companies have to include in Section 6.2 of their export notification in the IT tool ePIC.
The image above shows Section 6.2 for an export of creosote, CAS 8001-58-9 (which belongs to the PIC entry on creosote and creosote-related substances).
Authorities in non-EU countries rely a lot on the information provided in this section of the export notification when deciding whether or not to allow a certain import. Complete and accurate information about these uses gives non-EU authorities in the receiving countries a clearer and more comprehensive picture of how these substances are used in the EU. This information is valuable as the EU is considered to be a reliable source of information.
“Our experience has shown that many companies fail to report the prohibited and allowed uses correctly. They seem to be unaware of the regulatory measures concerning their substances and, for example, put the use for which they are exporting the product as allowed – although it might not be in the EU. Currently, we are requesting approximately 17 % of the export notifications to be resubmitted due to errors in this field, which means that on a yearly basis we handle around 8 000 export notifications, of which 1 350 need to be resubmitted. This is not sustainable for the companies, ECHA or the designated national authorities,” says Chiara Macchi, ECHA’s PIC team leader.
The Agency now aims to help companies with their notifications by providing clarity on what the section is about, on how it should be used and, where possible, practical examples on how to fill in the relevant section correctly.
Better notifications will save exporting companies time, as requests to resubmit will be less likely, and will also reduce ECHA’s administrative burden.
“Another result is that countries to which the substances are imported will get reliable information to enable them to make sound decisions on imports. After all, the aim of PIC is to share information on hazardous chemicals between countries and promote shared responsibility and cooperation in international trade,” says Ms Macchi.
Five top tips
The guidelines will be published in early October on ECHA’s website. However, we already want to share five top tips for completing Section 6.2 of the export notification:
- Section 6 refers to the regulatory situation (including the allowed and prohibited uses) in the EU and not in the country of destination of the export.
- The information provided should be clear, to the point and not misleading.
- When exporting a mixture, the information provided must refer to the PIC substance it contains and not to the mixture as a whole (or to other non-PIC components in the mixture).
- If a reference to a legal text is provided, it must be correct and complete to allow the recipient to identify the source document. For example, if a substance is subject to PIC because it has been restricted under REACH, a complete reference to the REACH restriction (including the entry number) should be provided.
- If specific uses are provided, they should be relevant in the context of the PIC Regulation - for example, stating that a certain PIC chemical is banned for military use is not considered relevant in the context of the PIC Regulation, which specifically deals with industrial chemicals, plant protection products and biocides.
ECHA to improve the regulatory summaries in the export notifications
In addition to working on the guidelines, ECHA is currently improving Section 6.1 on the summary of the final regulatory action and ensuring that all translations are in place. This section summarises how the exported substance is regulated in the EU.
|The image above shows Section 6.1 for an export of ethylene oxide, CAS 75-21-8.|
These summaries are automatically inserted in export notifications in English, Spanish or French, depending which language is the most relevant in the country to which the substance is being exported. For example, if you are notifying an export of ferbam to Paraguay, the text highlights the EU legislation that regulates the use of ferbam in Spanish. The improved summaries are already in place for approximately 50 entries (starting with the most exported substances) and the rest will be finalised by ECHA in the coming months.
Did you know?
A new amendment to the PIC Regulation is expected before the end of the year. Substances will be added to Annex I and will be subject to the export notification and to the explicit consent procedure to be exported. The added substances are those that are included in the REACH Authorisation List and substances not approved under either the Plant Protection Products Regulation or the Biocidal Products Regulation.
In addition, the list of chemicals and articles which are banned in the EU and should not be exported (Annex V) will be updated with the next amendment. Developments under the Stockholm Convention on persistent organic pollutants (POPs) and to the POPs Regulation will be taken into account and the amendment will also reflect the recent changes introduced by the EU regulation on mercury. Once the amendment enters into force, ePIC will also be upgraded to enable exporters to comply with their obligations in relation to the export of certain mercury compounds.
The update will keep the existing total export ban on metallic mercury and make the export of more mercury compounds subject to specific conditions.
Interview by Hanna-Kaisa Torkkeli
Published on: 13 September 2018
Top image: © istock.com/andresr
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1-4 and 8-11 June (tentative);
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