Positioning of the Member States: where do we stand?
We provide you with an update on the different positions of the Member States regarding the implementation of Annex VIII of the CLP Regulation, based on ECHA's table of Member States' decisions.
Poison Centre Notifications: which States are connected to the ECHA portal?
Firstly, Member States have the choice of whether or not to accept notifications via the ECHA portal. Some of them have already started to change their systems, but others prefer to keep their national systems for the time being.
Member States already connected to the ECHA portal: companies can start notifying their mixtures on the plateformAustria, Croatia, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Netherlands, Norway, Poland, Portugal, Slovenia, Sweden, Spain, Malta, Romaniaountries that retain their own systems for the time being: companies must continue to notify via the national system until further noticeBelgium, Bulgaria, Czech Republic, Iceland, Liechtenstein, Luxembourg, Slovakia
Poison centre notifications: which portal to choose according to States?
After confirming their notification system, Member States can accept notifications through their national portal or the ECHA portal. For mixtures intended for industry, some countries still accept submissions via their national platform even if they are connected to the ECHA platform (Ireland, Italy, and Sweden).
Notification accepted only through the ECHA portal, once connection is confirmedAustria, Croatia, Cyprus, Denmark, Estonia, Greece, Hungary, Iceland, Ireland, Italy, Lithuania, Malta, Netherlands, Norway, Poland, Slovakia, Slovenia, Spain, SwedenNotification accepted by ECHA portal or national systemBelgium, France, Germany, Latvia, Portugal, FinlandNo information provided Bulgaria, Czech Republic, Liechtenstein, Luxembourg, Romania
Poison centre notifications: what language should I use for my notification?
The Member States have then defined the language in which they will accept notifications..
Official language of the Member State or English Belgium, Croatia, Denmark, Estonia, Germany, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Portugal, Spain, SwedenOfficial language of the Member State onlyAustria, Bulgaria, Cyprus, Czech Republic, France, Greece, Hungary, Liechtenstein, Poland, Romania, Slovakia, Slovenia
Poison centre notifications: do I have to pay a notification fee?
Some Member States have decided not to charge a fee when notifying the Poison Centre, others are considering charging a fee in the future and some countries have not yet decided. Several countries apply fees: it is necessary to contact the local authorities or to make the necessary arrangements locally.
No feeAustria, Bulgaria, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Iceland, Ireland, Latvia, Lithuania, Malta, Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, Sweden, Spain, Czech Republic, RomaniaFees applicable according to the designated body of the Member StateHungary, Italy, FinlandFees under considerationCroatiaNo information Belgium, Liechtenstein, Luxembourg
Poison centre notifications: can I proceed with the placing on the market as soon as my mixtures are notified?
Finally, Member States can then take several possible routes for placing mixtures on the market once notified..
The notifier can place the mixture on the market immediately after confirmation that the dossier has passed the automatic validations of the portalAustria, Croatia, Cyprus, Denmark, Estonia, Finland, Greece, Hungary, Iceland, Ireland, Lithuania, Malta, Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, Sweden, RomaniaThe notifier may place the mixture on the market after confirmation that the dossier has been received by the designated body of the Member StateFrance, Germany, Italy, SpainNo information Belgium, Bulgaria, Czech Republic, Liechtenstein, Luxembourg
ECHA's notification portal
Annex VIII was published in March 2017 and requires all mixtures hazardous to health or having physical effects to be notified to Member State poison centres in the harmonised PCN (“Poison Centre Notification”) format. The first deadline was for consumer and professionals mixtures in January 2021 mixtures and January 2024 for industrial mixtures only. In the case of products with several uses, the earliest expiry date should be taken into account. Therefore, all mixtures previously notified to the Member States before those dates can benefit from the transitional period, which will end on 1st January 2025, unless otherwise indicated.
Prior to the entry into force of Annex VIII, each Member State had set up its own system for receiving notifications. Some were free of charge, others had to be paid for, the formats could vary, etc.
Since April 2019, ECHA has set up an online tool to facilitate the creation and submission of dossiers for notifications to the Poison Control Centres (PCN) for the industry. New obligations for reporting, labelling (with the UFI code) and transmission of information within the supply chain apply since then.
ECHA was therefore keen to harmonise notification systems, however, many countries continue to rely on their own systems and have not yet moved to the ECHA portal.
Wish to know more about poison centres notification?
For more information, do not hesitate to contact Renaud Germain-Thomas or one of our experts !
