Understanding PIC – ECHA

The Prior Informed Consent Regulation governs the trade of certain hazardous chemicals that are banned or severely restricted in the EU. It places obligations on companies that wish to export these chemicals to non-EU countries or import them into the EU.

PIC implements the Rotterdam Convention within the EU. It promotes shared responsibility and cooperation in the international trade of hazardous chemicals. It also protects human health and the environment by providing importing countries with information on how to store, transport, use and dispose of hazardous chemicals safely.

PIC entered into force on 1 March 2014.

What is covered?

• Banned or severely restricted chemicals listed in Annex I to the PIC Regulation :
  • Active substances in pesticides (e.g. atrazine or permethrin) or in biocidal products such as disinfectants, insecticides or parasiticides (e.g. malathion or didecyldimethylammonium chloride)
  • Industrial chemicals (e.g. benzene or chloroform)
• Chemicals that are banned for export from the EU listed in Annex V to the PIC Regulation (e.g. persistent organic pollutants or some mercury compounds).

Under PIC (Article 17), the packaging and labelling of all exported chemicals – whether they are banned or severely restricted within the EU or not – must comply with the Classification, Labelling and Packaging (CLP) Regulation.

What is not covered?

• These are regulated by other specific EU legislation:
  • Narcotic drugs and psychotropic substances
  • Radioactive materials
  • Wastes
  • Chemical weapons
  • Food and food additives
  • Feeding stuffs
  • Genetically modified organisms
  • Proprietary medicinal products and those veterinary medicinal products that are not disinfectants, insecticides and parasiticides.
• Chemicals exported or imported for research or analysis if the quantities are unlikely to affect human health or the environment and do not exceed 10 kilograms per exporter to each importing country per calendar year.

Notifying exports and receiving permission to export

Companies intending to export chemicals listed in under PIC to non-EU countries, need to notify their intention to export (see Export notification procedure) and get a confirmation that the export is allowed before it can take place (see Explicit consent requirement).

Reporting obligations

Each year, importers and exporters of PIC chemicals need to send their designated national authorities information on the exact quantities of the chemical shipped to or from each non-EU country during the preceding year (see Annual reporting on PIC exports and imports).