I am an exporter – what do I do?


Exporters must notify 2017 exports of PIC chemicals using ePIC  before 23rd March to allow time for processing .

  • ECHA have advised that “the legal deadline will NOT be extended further this year” 

  • This Article 10 report is not required for research or analysis chemical exports less than 10kg

The Authority will have reduced cover for PIC chemicals from 27th March to 3rd April

Commission delegated Regulation (EU) 2018/172 amending annexes I and V to the PIC Regulation will apply from 1 April 2018. Companies can notify in advance through ePIC.

Chemicals listed

Annex I to Regulation (EU) No 649/2012 (further amended by Regulation (EU) 2018/172) has three parts listing chemicals that are banned or severely restricted within the EU. Annex I indicates if the chemical use is pesticide and/or industrial chemical. Different provisions apply depending on the part of Annex I.

These chemicals require an active Reference Identification Number (RIN) issued from ePIC before the export or import can proceed.

Exporters and importers must notify yearly exports and imports of these PIC chemicals using ePIC, before 31st March the following year.

To find out if Regulation (EU) No 649/2012 (further amended by Regulation (EU) 2018/172) applies to your chemical:

  1. Go to ECHA's webpage on chemicals subject to PIC and search for the chemical
  2. Identify if the chemical is Part 1, Part 2 or Part 3 and follow the path below
Part 1 Chemicals ProcedurePart 2 Chemicals ProcedurePart 3 Chemicals Procedure

Procedure for Part 1 Chemicals | Procedure for Part 2 Chemicals | Procedure for Part 3 Chemicals | Special RIN Procedure

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Special RIN Procedure

Special Reference Identification Number (RIN) requests for pesticides are dealt with by the Department of Agriculture, Food & the Marine.

Special RIN requests for industrial chemicals are dealt with by the Health & Safety Authority.

Article 2(3) Special RIN (under 10kgs for research/analysis)

Regulation (EU) No 649/2012, as amended shall not apply to chemicals exported for the purpose of research or analysis in quantities that are unlikely to affect human health or the environment and that in any event do not exceed 10 kg from each exporter to each importing country per calendar year.  Exporters of the chemicals still need to obtain a special RIN using ePIC and provide that special RIN in their export declaration.

The exporter should

  • apply for the Special RIN at least 35 days before the date of export of the chemical
  • receive an active Special RIN* if everything is in order
  • include the active Special RIN* either in box 44 of the Single Administrative Documents (SAD), or in the corresponding data element in an electronic export declaration

*IMPORTANT ADVICE - An active RIN means a RIN that has customs clearance. Not all RINs are activated. Inactive RINs may be issued automatically.

See Special RIN Requests In Brief (ECHA, November 2017)

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