As of April 24, companies can access a new online-tool provided by the ECHA that supports the preparation and transmission of data on hazardous mixtures. Companies can create information in PCN format, which is compatible with IUCLID and transmit it to the responsible agencies in member states. The agencies then provide the information to poison centers, which can provide rapid medical advice in the event of an emergency. The tool significantly reduces the administrative efforts required of companies that market their mixtures in multiple countries and must therefore transmit information to several member states.
But there is one catch: The current version offers only basic information, and an enhanced version is to be released only at the end of the year. That does not give companies much time to act, given that Regulation (EU) 2017/542 takes effect on January 1, 2020. Annex VIII is the sticking point of the Regulation. Article 1 of the Annex states that importers and downstream users have an obligation to provide information on mixtures for consumer use as of January 1, 2020. These mixtures are responsible for most emergency calls. The obligation to provide information on mixtures for professional use applies as of January 1, 2021, and it applies for mixtures used industrially as of January 1, 2024.
Because of the short time available, the Chemical Industry Council (German only) and several other associations have called for an extension of the requirement, particularly because of the tremendous effort that companies must expend to provide the information. For example, each recipe requires the creation of a Unique Formula Indicator (UFI) code that must appear on the label and the safety data sheet. Because formulators and importers are dependent on the information provide by their vendors, some uncertainly also exists.
Companies can reduce their administrative effort by keeping their safety data sheets up to date at all times. We can offer concrete advice on this task.
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