The Regulation (EU) 649/2012, commonly referred to as the PIC Regulation (Prior Informed Consent), lists in Annex I the chemical substances subject to export notification and prior informed consent procedures. These procedures must be followed before exporting such substances to third countries, particularly for substances banned or severely restricted by EU legislation or covered by the PIC procedure under the Rotterdam Convention.
The substances included in Annex I are subject to notification obligations. Companies intending to export these substances to non-EU countries must submit a notification to the competent authorities in the country of export, and in some cases, wait for the importing country’s consent.
It is crucial to conduct an analysis of the substances handled by the company and implement the appropriate regulatory actions, which include:
- Identification of substances, mixtures, and articles falling within the scope of the PIC Regulation.
- Creation of an ePIC account.
- Export notification for substances or mixtures intended for research or analysis purposes (special RIN request).
- Export notification for substances listed in Part 1 of Annex I or mixtures containing such substances in concentrations triggering CLP labeling requirements (standard RIN request) under Article 8.
- Export notification for substances listed in Part 2 of Annex I or mixtures containing such substances in concentrations triggering CLP labeling requirements, also subject to the PIC procedure under Article 11.
- Authoring of a safety data sheet compliant with Annex II of the REACH Regulation.
- Reporting volumes related to the export and import of chemical substances under Article 10 of the PIC Regulation.