Annex VIII harmonized poison centre notifications (PCN) was first implemented from January 1, 2021, for consumer and professional users. Importers, downstream users and distributors placing hazardous mixtures on the European markets must notify the ingredients in those mixtures classified as hazardous for physical or health effects.

This requirement is not new, it has existed for years, but before Annex VIII, each Member State managed its own system and established their own requirements, which varied on the type of information provided, the mechanism of notification, the language or the formats. Annex VIII introduced a new harmonized format for notifications.

Each Member State is implementing the regulations with slight differences and different schedules. In order to facilitate companies the notification process the ECHA has published a visual summary document that shows the status of each Member State — Overview of Member States decisions in relation to implementation of Annex VIII to CLP Regulation (Poison Centre Notification).

The document centre in 5 keys categories in relation to the implementation of Annex VIII of CLP:

• •Readiness of Member State to accept notifications via ECHA submission portal.
• •Submission system options.
• •Notification language.
• •Fees for notifications.
• •Placing on the market mixtures notified via ECHA submission portal.

The ECHA has just released the document´s latest version 6.3 on Mars 2021, and we show you below the main novelties introduced in each of the five categories:

• 1. Readiness of Member State to accept notifications via ECHA submission portal.

• To date, most member states accept notifications via ECHA submission portal, but there are still 10 countries that have not moved yet from their national systems to the ECHA submission portal: Belgium, Bulgaria, Czech Republic, Iceland, Liechtenstein, Luxembourg, Malta, Romania and Slovakia. In the case of Spain, the national system remains open until it is fully prepared to process all submitted dossiers via ECHA submission system.

• 2. Submission system options. There are three possible submission options at the moment:
• a) Member states that will only accept notifications via ECHA submission portal: Croatia, Cyprus, Denmark, Estonia, Finland, Greece, Hungary Iceland, Lithuania, Malta, Netherlands, Norway, Poland, Romania, Slovakia and Slovenia. In the case of Austria, Ireland, Italy, Spain and Sweden their national systems will remain open for industrial mixtures, in principle, until January 1, 2024, the end of the transitional period to harmonize with the European system.
• b) Member States that will accept notifications both via the ECHA Submission or their national submission system: Belgium, France, Germany, Latvia and Portugal.
• c) Member States that have not yet informed ECHA of their decision: Bulgaria, Czech Republic, Liechtenstein, Luxembourg and Romania.
• 3. Notification language.

• Most Member States will accept English or their local language. However, 13 of these Member States accept only their local language and require companies to translate all sections containing toxicological information. These countries are: Austria, Bulgaria, Cyprus, Czech Republic, Finland, France, Greece, Hungary, Liechtenstein, Poland, Romania, Slovakia and Slovenia.

• 4. Fees for notifications.

• At the moment, only Hungary, Italy and Belgium are charging fees for notifications, but Croatia and Spain are taking it into consideration. These are the fees and the information links for Hungary, Italy and Belgium:

• Hungary: 16,000HK per product / per year
• Italy: 50€ per company / per year
• Belgium: 200€ or 35€ per product / one-time fee
• For further information, you can access the links to visit the official websites.
• 5. Placing on the market mixtures notified via ECHA submission portal.
• In most member states companies can start placing the mixture on the market immediately after confirmation in the submission report that the dossier has passed the automated validation checks in the ECHA portal, but some other requires confirmation in the submission report that the dossier has been received by the Member State appointed body. This is the case of France, Germany, Italy and Spain, although there are also many countries considering to include this requirement.

CHEMETER, our safety data sheet software, offers periodic updates and is already in full development of new functionalities to adapt to the latest regulations and provisions to help companies to notify following some simple steps.