The European Chemicals Agency (ECHA) has reminded companies of their obligation to submit annual reports under Article 10 of the Prior Informed Consent (PIC) Regulation (EU) No 649/2012.
EU exporters and importers must report the quantities of PIC chemicals actually traded with non-EU countries in 2025 by 31 March 2026.
Scope of the Obligation
Under Article 10 of the PIC Regulation, companies established in the EU must inform their designated national authorities (DNAs) of the quantities of PIC chemicals they have exported to or imported from non-EU countries. This obligation applies to chemicals listed in Annex I of the PIC Regulation, whether they are traded as substances, in mixtures, or in articles. Reporting must be completed electronically via ECHA’s ePIC IT tool.
Reporting on Exports
For exporters, ePIC automatically generates a pre-filled report on 1 January if export data for the previous calendar year exists in the system. The report includes:
- Validated export notifications
- Certain special RIN requests for Annex I Part 3 chemicals where applicable
- Special RIN requests for countries that have waived their right to receive export notifications.
Companies must complete the report by:
- Confirming actual quantities exported.
- Reporting “nil” quantities where a notified export did not take place.
- Providing full importer details.
- Reporting quantities in kilograms (kg) or litres (l).
- Indicating the quantity of the Annex I substance contained in a mixture or article.
Exports not previously notified must be entered manually. Exports of less than 10 kg per year and per importing country for research and analysis purposes are exempt from the reporting obligation.
Reporting on Imports
Import reports must be created manually in ePIC and follow the same format as export reports. Imports below 10 kg per year and per exporting country for research and analysis purposes are also exempt.
Submission and Deadlines
Companies will receive a reminder via ePIC ahead of the 31 March deadline. After this date:
- New reports cannot be created.
- Only resubmissions of previously submitted reports are possible.
Companies that miss the deadline are instructed to contact their DNA.
DNAs must compile national reports and submit aggregated data to ECHA by 30 September 2026. ECHA will subsequently publish a non-confidential EU-level summary report on its website by the end of the year.
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