The EU Prior Informed Consent (PIC) Regulation controls the export and import of certain hazardous chemicals. The lists of chemicals subject to the Regulation were amended from 1 October 2026, while a forthcoming EU enforcement pilot will examine exporters’ compliance with notification, consent, reporting and other PIC requirements.
Companies planning exports in early 2027 should review their portfolios and prepare the necessary notifications in advance. For a first yearly export planned for 1 January 2027, the statutory 35-day notification period results in a submission deadline of 27 November 2026. We recommend submitting by mid-November to allow for a practical margin for authority review and any necessary corrections.
Key takeaways
- Scope: The EU PIC Regulation applies to the export and import of certain hazardous chemicals.
- Updated lists: The lists were amended from 1 October 2026, with additional 34 chemicals or chemical entries becoming subject to export notification.
- Annual notification: Listed chemicals, and mixtures above applicable concentration thresholds, must be notified before the first export in each calendar year.
- Consent and decisions: Depending on the Annex I listing, explicit consent or compliance with an importing-country decision may also be required.
- 2027 timing: For a first export on 1 January 2027, the 35-day notification deadline is 27 November 2026. We recommend notifying by mid- November to allow for review, corrections and potential end-of-year closure periods.
- Annual reporting: Exporters and importers report previous year’s quantities by 31 March of the following year.
- Enforcement: A forthcoming EU pilot project will examine notification, consent, reporting and related export requirements.
What is the EU Prior Informed Consent Regulation?
Regulation (EU) No 649/2012 concerning the export and import of hazardous chemicals, generally referred to as the Prior Informed Consent or PIC Regulation, implements the Rotterdam Convention within the European Union. Its purpose is to promote shared responsibility in the international trade of certain hazardous chemicals and support the exchange of information concerning their characteristics and safe use.
The Regulation applies principally to:
- chemicals listed under the Rotterdam Convention;
- chemicals that are banned or severely restricted within the EU; and
- chemicals whose export is prohibited under EU law.
The chemicals covered by the PIC Regulation fall into two broad use categories, each divided into subcategories:
- Industrial chemicals
- chemicals for use by professionals; and
- chemicals for use by the public.
- Pesticides
- pesticides used as plant protection products; and
- other pesticides, including biocides.
The applicable category and subcategory form part of the Annex I entry and may affect whether a proposed export is covered. Exporters should therefore assess the chemical’s intended use in the importing country rather than relying only on its identity or CAS number.
In this context, an export means sending a chemical from the EU to a third country. Shipments from the EU to Great Britain are therefore exports for the purposes of the PIC Regulation.
The requirements are not limited to individual substances. Depending on their composition and the applicable concentration thresholds, mixtures may also be covered. Certain articles containing PIC chemicals in an unreacted form may require export notification under the conditions set out in Article 15 of the Regulation.
Which chemicals are subject to PIC?
Chemicals subject to PIC requirements are listed in Annex I to Regulation (EU) No 649/2012. Annex I is divided into three parts, with different requirements applying to each.
For a complete and easy to use overview, consult ECHA’s Chemicals subject to PIC list, which can be searched by chemical name, EC or CAS number and shows the relevant Annex entry, use category and restriction.
Annex I Part 1: export notification
Chemicals listed in Part 1 are subject to the export notification procedure. The exporter must notify the Designated National Authority of the Member State in which it is established before the first export of the chemical in each calendar year.
Annex I Part 2: export notification and explicit consent
Part 2 covers chemicals that qualify for PIC notification under the Rotterdam Convention. These chemicals are subject to export notification and may also require the importing country’s explicit consent before export.
Annex I Part 3: chemicals subject to the Rotterdam Convention PIC procedure
Part 3 lists chemicals subject to the international PIC procedure. Exporters must comply with the applicable import decision published for the importing country.
Where no response has been provided, the Regulation’s explicit-consent provisions and any permitted waiver arrangements must be considered.
The inclusion of a chemical in Annex I establishes that it is regulated, but the relevant part of the Annex, use category and subcategory, concentration threshold and intended use determine the applicable requirements.
Annex V: chemicals banned for export
Separately, Annex V lists chemicals and articles whose export is prohibited.
Exporters should therefore screen proposed exports against both Annex I and Annex V.
PIC chemical lists updated from 1 October 2026
Commission Delegated Regulation (EU) 2026/1278 amended and corrected pesticide and industrial-chemical entries under Regulation (EU) No 649/2012. The amendment applies from 1 October 2026.
The amendment added 34 chemicals or chemical entries to the export notification procedure and amended certain existing entries to reflect changes in their regulatory status. The additions include pesticides and industrial chemicals that have been banned or severely restricted within the EU.
The new entries were added to ePIC before the application date, allowing exporters to prepare and submit notifications for exports planned from 1 October 2026 onwards.
Companies exporting substances, mixtures or relevant articles outside the EU should screen their portfolios against the updated Annexes. This review should not be limited to products marketed as hazardous chemicals. It should also consider:
- mixtures containing listed chemicals above the applicable thresholds; and
- where relevant, articles containing listed chemicals in an unreacted form.
What must an EU exporter do?
Submit an export notification
An exporter of a chemical listed in Annex I must submit an export notification through ePIC, ECHA’s IT system for implementing the PIC Regulation.
The notification is submitted to the exporter’s Designated National Authority. It is required before the first export in a calendar year and must be renewed before the first export in each subsequent calendar year.
Article 8 requires the exporter to submit the notification at least 35 days before the expected export date. For subsequent calendar years, it must similarly be submitted at least 35 days before the first export in that year.
2027 timing example
If a company plans its first export of 2027 for 1 January 2027, the notification must be submitted by 27 November 2026. As a practical compliance target, submission by mid-November would provide additional time for authority review and the correction of incomplete or inaccurate information as well as allow for the end-of-year closure periods.
Once the notification has been processed, a Reference Identification Number, or RIN, is assigned. The exporter must use the applicable RIN in the relevant customs declaration.
Determine whether explicit consent is required
For certain Annex I chemicals, submitting an export notification is not sufficient. The exporter may also need confirmation that the importing country consents to the import.
The applicable requirement depends on:
- the chemical’s Annex I listing;
- its intended use category;
- any published importing-country decision; and
- whether an explicit-consent requirement, waiver or other permitted arrangement applies.
An exporter should not treat the submission or acceptance of an export notification as confirmation that the export may proceed. The applicable import decision, explicit consent, exemption, waiver or prohibition must be assessed separately.
Check export prohibitions
Certain hazardous chemicals and articles are subject to an EU export prohibition under Annex V. Such exports cannot proceed unless a specific exemption provided by the Regulation applies.
The Annex V assessment should be a distinct part of the exporter’s review. The ability to prepare an ePIC notification does not, by itself, establish that the proposed export is permitted.
Meet packaging and information requirements
Chemicals exported under the PIC Regulation remain subject to applicable requirements concerning:
- classification;
- packaging and labelling;
- expiry and production dates, where relevant; and
- safety data sheets.
As far as practicable, information on labels and safety data sheets should be provided in an official language, or one or more of the principal languages, of the importing country.
PIC compliance must therefore be coordinated with the exporter’s classification, labelling, packaging and safety data sheet arrangements.
Annual reporting of exports and imports
Article 10 requires exporters and importers to report the quantities of listed chemicals exported to or imported from each third country during the previous calendar year.
The information must be submitted to the relevant Designated National Authority during the first quarter of the following year. Reporting is completed through ePIC.
Companies should retain sufficient information to reconcile:
- substances and mixtures covered;
- destination or origin countries;
- quantities actually exported or imported;
- applicable Annex I entries;
- export notifications and RINs; and
- explicit consent, waiver or import-decision documentation.
The annual report should reflect the quantities actually exported or imported, rather than the quantities forecast when the export notification was prepared.
EU enforcement pilot will examine PIC compliance
A forthcoming EU enforcement pilot will focus on exporters’ compliance with the PIC Regulation.
The pilot will examine:
- export notifications;
- compliance with the PIC procedure;
- export exemptions and prohibitions;
- Article 10 reporting;
- information accompanying exported chemicals; and
- applicable packaging, labelling and safety data sheet requirements.
The operational phase – actual inspections – is scheduled to run from 1 November 2026 to 15 May 2027.
The pilot gives exporters an immediate reason to check that their records are consistent across:
- substance and product screening;
- ePIC submissions;
- explicit-consent documentation;
- RINs and customs declarations;
- annual quantity reporting; and
- labels and safety data sheets supplied with exported chemicals.
What should exporters do now?
- Identify substances, mixtures and relevant articles exported outside the EU.
- Screen the portfolio against the current Annex I and Annex V listings, including the changes applicable from 1 October 2026.
- Confirm the applicable use category, subcategory and concentration threshold for each potentially relevant entry.
- Determine whether export notification, explicit consent, an import decision or an export prohibition applies.
- Review the timing of planned exports, particularly the first export expected in 2027.
- Submit notifications at least 35 days before the expected export date, allowing additional time for review and corrections where practicable.
- Check consistency between ePIC notifications, RINs and customs records.
- Confirm that packaging, labels and safety data sheets meet the applicable export requirements.
- Prepare the records needed for Article 10 reporting during the first quarter of the following year.
A substance list match is the start of the assessment, not the final conclusion. The Annex entry, intended use, product composition, importing country and timing of export may all affect the resulting obligation.
H2 Compliance support
H2 Compliance can support companies in assessing and managing their obligations under the EU PIC Regulation, including:
- screening exported substances and products against the current PIC lists;
- determining the relevant Annex entries and applicable requirements;
- assessing export-notification and explicit-consent obligations;
- preparing and submitting export notifications through ePIC;
- reviewing export prohibitions and potentially applicable exemptions;
- supporting annual Article 10 reporting; and
- reviewing PIC compliance processes and supporting documentation.
Companies exporting hazardous chemicals outside the EU should establish the applicable requirements before the proposed export takes place. For support with PIC screening, export notifications or annual reporting, contact the H2 Compliance chemical regulatory team.
Published October 27st, 2026
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