22 substances are now subject to export notifications under the Prior Informed Consent (PIC) Regulation includng19 new entries, three of the entries (diquat, glufosinate, and propineb) cover two substances each. 20 of the 22 substances also need consent from the authorities of the importing country before they can be exported.

EU exporters who want to export any of the substances after 1 September 2020, as such or in mixtures, need to notify their designated national authority of their intention at least 35 days before the date of their first imports and exports to and from the EU.

Reason to Notify:

The majority of the 22 substances have been added to the PIC Regulation because they are banned as active substances in plant protection products within the EU. Some are also severely restricted under the Biocidal Products Regulation and, approved only for a limited number of biocidal products.

Major substances to be added:

● The pesticide phorate has been added following its listing under the Rotterdam Convention in 2019. Exports of phorate now require an export notification.

● One substance (imidacloprid) is also used in veterinary medicinal products. Furthermore, a series of mercury-containing articles have also been added to Annex V to PIC, and exporting them from the EU is now banned. Besides, two mercury compounds have been added and their export is now only allowed for uses in laboratory-scale research and analysis.

● The industrial chemical hexabromocyclododecane (HBCDD) has also been added to Annex I, Part 3 to PIC following its listing under the Rotterdam Convention in 2019. However, as HBCDD is already listed under Annex V to PIC, exports of it from the EU are banned.

On 24 September 2020, ECHA will host an online information session to explain the scope and main requirements of the PIC Regulation, as well as the actions exporters need to take to comply with the regulation – from notifying to reporting.




If this regulation is applicable to you and you are interested in knowing more about this topic and available solutions, then schedule a free consult with our experts.