Sample Scenario 1

A manufacturer in Ireland intends to export for the first time hexachloroethane to Cameroon. Hexachloroethane is listed in Part 1 of Annex I to the PIC Regulation because it is severely restricted for industrial use.

It appears that the chemical has not previously been exported from the EU to Cameroon. Hexachloroethane is an industrial chemical, not a pesticide.

Procedure:

  • The exporter must submit an export notification supplying the information set out in Annex II to the PIC Regulation to the Irish Designated National Authority (DNA) [in this case the DNA would be the Health and Safety Authority because it is an industrial chemical] at least 35 days before the export
  • Having established that the export notification is complete, the HSA promptly forward the export notification. Having verified that no EU export notification has already been made for that calendar year, the CPSQ sends the export notification to Cameroon
  • The exporter will get the relevant reference identification number (RIN) and must include it in his customs declaration
  • The chemical must be packaged and labelled as it has to be in the EU. The exporter shall send a safety data sheet to the importer
  • The label and safety data sheet should be printed in English and French (the two official languages as well as the languages used by Cameroon in international communications)

Sample Scenario 2

Irish company Chemoproducts wants to ship boron trichloride to Russia. Boron trichloride is not listed in Annex I to the PIC Regulation, but has been listed in Annex VI of Regulation EC No 1272/ 2008 on the classification, labelling and packaging of substances and mixtures.

Procedure:

  • The exporter does not need to provide any information to either of the Irish DNAs. The export may take place without export notification or consent from the importing country
  • The chemical must be packaged and labelled according to EU legislation. A safety data sheet shall be sent to each importer. All information should be in Russian (the official language) and English (an EC language used in international communications)

Sample Scenario 3

Irish company ABC Chemicals intends to export chloroform to Nigeria. Chloroform is listed in Part 1 to Annex I to the PIC Regulation and has been exported to Nigeria earlier in the year, but was never exported by ABC Chemicals before. Chloroform is an industrial chemical, not a pesticide

Procedure:

  • The exporter must submit an export notification supplying the information set out in Annex II to the PIC Regulation to the HSA (because this is an industrial chemical) at least 35 days before the export
  • Having established that the export notification is complete, the HSA forward the export notification. Provided that an EU export notification has already been made for that calendar year, the export notification is stored in the European Database Export Import of dangerous chemicals (EDEXIM) without any further action
  • The exporter will get the relevant reference identification number and must include it in his customs declaration
  • The chemical must be packaged and as it has to be in the EU. The exporter shall send a safety data sheet to each importer
  • The label and safety data sheet should be printed in English

Sample Scenario 4

Irish company LongShip intends to export PCTs to Gambia, which is a Party to the Convention. PCTs are listed in Parts 1 and 3 to Annex I to the PIC Regulation. Gambia has reported an import decision in the latest update of the PIC Circular, giving consent.

Procedure:

  • The exporter does not need to submit an export notification and can proceed with the export
  • The exporter will make a request for a reference number via the appropriate DNA [HSA for industrial chemicals and Pesticide Registration and Control Division for pesticides] and once he receives it he must include it in his customs declaration
  • The chemical must be packaged and labelled according to EU legislation. A safety data sheet shall be sent to each importer. All information should be in English
  • The exporter should however bear in mind that, as with all chemicals listed in Annex I, he must, during the first quarter each year, inform the appropriate DNA of the quantities of PCTs shipped to Gambia during the preceding year (including name and address of each importer)

Sample Scenario 5

Company Killing Pest, based in Ireland, intends to import parathion-ethyl from Canada to produce a pesticide, and then export the preparation to Guatemala. Parathion-ethyl is banned in the EU for use as a pesticide or plant protection product. The substance is listed in Part 1 of Annex I to the PIC Regulation as well as Part 3 (being subject to the PIC procedure in the pesticides category). In the latest PIC circular the import decision for the EU is ‘no consent’. The import decision for Guatemala is ‘consent’.

Procedure:


Sample Scenario 6

Company Laboratory Analysis Products intends to export 100g nonylphenol for use in analysis in a laboratory to country L. Nonylphenol is listed in Part 1 and 2 of Annex I to the PIC Regulation and therefore explicit consent from the importing country would normally be required. Since the quantity of nonylphenol intended to be exported in 2011 to country L is less than 10kg and not considered likely to be affect health or the environment as it is used under laboratory conditions for analysis, the export falls under Article 2.3 of Regulation (EC) 649/2012 and is therefore exempt from the PIC Regulation. However, in order to avoid difficulties at customs clearance a special procedure was established to get an activated Special Reference Identification Number (RIN).

Procedure:

  • The exporter must submit an Special RIN application form to the Irish DNA [in this case the DNA would be the Health and Safety Authority because nonylphenol is an industrial chemical] at least 35 days before the export
  • Having established that the Special RIN application form meets the requirements of Article 2.3, the HSA request an activated Special RIN.
  • The HSA will communicate the relevant Special RIN to the exporter, who must include it in Box 44 of his Single Administration Document (SAD) or corresponding data element in your electronic export declaration, for presentation to Customs Authorities
  • The chemical must be packaged and labelled as it has to be in the EU. The exporter shall send a safety data sheet to the importer.
  • The label and safety data sheet should be printed in the official language, or in one or other of the principle languages of the country of destination or of the area of intended use.

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