The Commission has proposed amendments to Annexes I and V of the Prior Informed Consent Regulation. Nineteen industrial chemicals for public use are proposed for addition — among them cobalt compounds, phthalates, bisphenol A and N,N-dimethylformamide — lead chromate is carved out as a separate entry, and three substances move to the export-ban annex. Feedback closed in August and adoption is expected this quarter.
What Happened
On 24 July 2026 the Commission published for feedback a draft Commission Delegated Regulation amending Regulation (EU) No 649/2012 as regards the listing of pesticides and industrial chemicals, reference Ares(2026)7318336. The Regulation implements the Rotterdam Convention on Prior Informed Consent and the Stockholm Convention on Persistent Organic Pollutants in EU law, and requires exporters of listed chemicals to notify and in some cases obtain the explicit consent of the importing country. Annex V listings are outright export bans.
What’s New
- Annex I, Part 1 (industrial chemicals for public use): 19 substances added, including cobalt compounds, phthalates, bisphenol A and N,N-dimethylformamide.
- Annex I, Part 1 (industrial chemicals): lead chromate added as a separate entry and removed from the existing ‘lead and its compounds’ entry.
- Annex I, Parts 1 and 2 (pesticides): flufenacet, acibenzolar-S-methyl, 2-methyl-1,2-benzisothiazol-3(2H)-one (MBIT), disodium octaborate tetrahydrate, diboron trioxide and boric acid added.
- Annex V, Part 1 (export bans): chlorpyrifos, medium-chain chlorinated paraffins (MCCPs), and long-chain perfluorocarboxylic acids, their salts and related compounds.
- Chlorpyrifos is simultaneously deleted from Annex I Parts 1 and 2 as it moves to the export-ban annex.
Key Dates & Timeline
Draft act published for feedback
Feedback period closed
Planned adoption, followed by Parliament and Council scrutiny
Date of application under Article 2 of the draft
Affected Industries
All · Chemicals · Coatings and pigments · Plastics and polymers · Batteries · Electrical and electronic equipment
Who Is Affected
EU exporters of the listed substances and of mixtures containing them above concentration triggers; designated national authorities; regulatory affairs and trade compliance teams; formulators supplying non-EU plants.
Standards / Products in Scope
Substances and mixtures listed in Annexes I and V to Regulation (EU) No 649/2012 when exported from the EU, including cobalt compounds, phthalates, bisphenol A, N,N-dimethylformamide, lead chromate, MCCPs and long-chain PFCAs.
Prohibitions, Restrictions & Requirements
Annex I listing triggers export notification and, for Part 2 and Part 3 substances, explicit consent requirements. Annex V listing is a prohibition on export — once MCCPs and long-chain PFCAs are listed, they may not be exported from the EU at all.
What Companies Should Do
- Screen your EU-origin export portfolio for the 19 added industrial chemicals — cobalt compounds, phthalates and bisphenol A are common in automotive coatings, plasticised parts and electronics.
- Treat the MCCP and long-chain PFCA export bans as a sourcing question for non-EU plants supplied from Europe, not just a paperwork change.
- Note that lead chromate becoming a discrete entry changes how it must be identified in export notifications.
- Build the application date into 2027 planning: entry into force plus two months, or 1 April 2027, whichever falls later.
PIC is easy to overlook because it governs exports rather than the EU market. This amendment reaches substances that are still widely present in automotive chemistries, and two of the additions are outright export bans rather than notification duties.
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