Over the past three years, the number of PIC notifications has increased from 4,500 in 2014 to almost 8,000 in 2016. In 2014, 390 companies issued notification of substances, and that number rose to 1,117 in 2016. The figures come from the first Report on the Operation of the Prior Informed Consent (PIC) Regulation 2017, published by the ECHA in August.
The PIC Regulation covers the export and import of chemicals that are forbidden or are allowed only with restricted use within the EU. Before such a substance can be exported into a non-EU country, notification must be entered in an ECHA database (ePIC). Furthermore, the country involved must expressly agree to the importation. If the authorities in the destination country approve, the substance can be exported from the EU. However, it must be labeled just as it would be in the EU, although in the national language of the receiving country. The goal of this kind of open communication is to simplify the creation of internal chemical management and other legal measures in non-EU countries – for employee safety, for example. For details on the PIC procedure and the parties responsible for it, visit the German Federal Institute for Occupational Safety and Health (Bundesanstalt für Arbeitsschutz und Arbeitsmedizin: BAuA – some information available in English).
The PIC Regulation implements the requirements of the Rotterdam Convention on trade in dangerous chemicals, plant protection products, and pesticides. The revised regulation (EU No. 649/2012) took effect in 2012.
Requests for permission to export from companies are often rejected. The number of reject requests rose in the last two years. The ECHA indicates that incomplete or incorrect entries in safety data sheets are the primary reason. In addition, descriptions and expressions given in the local language are often incorrect.
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