I am an exporter – what do I do?
- The EU Commission has extended the deadline for Article 10 reports, verifying the tonnage of PIC chemicals imported or exported outside the EU, from 31st March 2020 to 31st May 2020. The move has been made to accomodate companies who under present circumstances, may be struggling to meet their obligations.
- Regarding Brexit, the UK withdrew from the Union on the 31 January 2020. A transitional period will apply until 31 December 2020, however from 1 January 2021, the UK will become a third country and so exporters of Annex I chemicals will have notification and reporting obligations under the Regulation. For more information on Brexit, please visit our Brexit webpages.
Check if the chemical requires Prior Informed Consent (PIC)
- Check if the chemical is listed in the Annexes of Regulation (EU) 649/2012 (as amended).
- Double-check using the search facility from the European Chemicals Agency (ECHA).
- Check if the chemical is not exempt under Article 2, for example, wastes, foods.
- Register free on the online tool ePIC.
- Notify the export through ePIC at least 35 days in advance.
Annex I to Regulation (EU) 649/2012 (as amended) 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.
Export Notifications must be submitted 35 days in advance using ePIC.
These chemicals require an active Reference Identification Number (RIN) issued from ePIC before the export or import can proceed.
*IMPORTANT ADVICE - An active RIN means a RIN that has customs clearance. Not all RINs are activated. Inactive RINs may be issued automatically.
Exporters and importers must notify yearly exports and imports of these PIC chemicals using ePIC, before 31st March the following year. This Article 10 report is not required for research or analysis chemical exports less than 10kg
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) 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
See Special RIN Requests In Brief (ECHA, November 2017)
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