Getting ready for the upcoming Poison Centre deadline for industrial use only mixtures

Time has come for importers and downstream users of industrial use only mixtures to update their poison center notifications to fully comply with the harmonized information requirements outlined in Annex VIII to the CLP Regulation. Next January 1, 2024, the second poison center compliance phase comes into force, and it is essential for companies to fully understand the changes, requirements and implications that it implies.

First things first: what is the difference between industrial use mixtures and industrial use ONLY mixtures?

Industrial use ONLY mixtures englobe mixtures which are exclusively used in industrial sites and cannot be available as final product or in diluted form for consumer or professional users (MiM). For example, a pigment or a specific automotive paint which is only used in a car factory. Industrial use mixtures, on the other hand, are mixtures with a wider range of users because they can also be utilized by professionals and/or consumers, either as final products or through reformulation. The compliance date for harmonized notification of these industrial use mixtures was 2021 and must include all relevant user types.

New transitional period and modified mixtures

For industrial use only mixtures that have already been notified via national submission systems before the 2024 deadline, it has been established a transitional period until January 1, 2025, before updating the PCN notification. Thus, ECHA is offering stakeholders an extra time to adapt their processes to the new regulation . However, any modifications made to the composition, identifiers, classification, or toxicological information of already registered indtrustirl use only mixtures are subjected to the new harmonized format before being put into the market.

Harmonized information requirements: what is new?

To fulfill the harmonized information requirements outlined in Annex VIII to the CLP Regulation, importers and downstream users of industrial use only mixtures must provide comprehensive chemical composition details, toxicological information, product specifics, and the Unique Formula Identifier (UFI). Importantly, industrial use only mixtures have the option of a "limited submission". Briefly, limited submissions do not need to include packaging information but they must clearly state a contact name, telephone number and email address for rapid access about additional product information in case of emergency.

UFI: linking notification and labeling

The UFI serves as a critical link between the notification and the actual labeling of hazardous mixtures. For hazardous mixtures that are accessible to consumers or professionals, UFI number must appear on both the PCN notification and product labels. On the other hand, industrial use only mixtures could generally speaking limit UFI placement to the Safety Data Sheet.

Main use identification from EuPCS

Categorization ofe mixtures' main intended use, must be done according to the European Product Categorization System (EuPCS). Whether the mixture serves as an end- product or it is reformulated, selecting the appropriate EuPCS category is essential. We can help you in cases of uncertainty or request concerning EuPCS changes (i.e. adding a new use).

How can we help you in the process of preparing for this deadline?

As January 2024 rapidly approaches, the importance of understanding, preparing, and complying with the second poison center compliance phase cannot be overstated.

Siam, as a leading consultancy specializing in chemical legislation, helps your company to efficiently align with the latest regulatory updates in the realm of hazardous chemicals in Europe. We offer our clients cutting-edge digital solutions tailored to their specific industry needs, streamlining the intricate process of compliance with the ever-evolving European chemical regulations.

Ask about our notification module to poison centers. A simple and effective tool with which to create "PCN Dossiers" and UFI codes automatically in just a few clicks.

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