I am an exporter – what do I do?


See ECHA's "How to notify PIC exports to the UK after UK’s withdrawal from the EU"

  • Regulation (EU) 649/2012 does not restrict exports to the UK before 29th March
  • PIC chemical exports to non-EU countries should be notified 35 days beforehand
    • For exports on 30th March, the 35 day deadline was 23rd February

Article 10 requires exporters to notify non-EU exports of PIC chemicals in 2018 before 31st March 2019

Check if the chemical requires Prior Informed Consent (PIC)

  1. Check if the chemical is listed in the Annexes of Regulation (EU) No 649/2012 as amended.
  2. Check if the chemical is listed in the Annexes of Regulation (EU) 2018/172.
  3. For exports after 1st May 2019, check if the chemical is listed in the Annexes of Regulation (EU) 2019/330.
  4. Double-check using the search facility from the European Chemicals Agency (ECHA). 
  5. Check if the chemical is not exempt under Article 2, for example, wastes, foods.
  6. Register free on the online tool ePIC.
  7. Notify the export through ePIC at least 35 days in advance.

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

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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