I am an exporter – what do I do?
From April 2016 to May 2017, 90 additional chemicals were added to the group entries in Annex I to PIC. A list of these chemicals is in the column on the right on ECHA’s website. Updating the group entries with individual chemicals and their identifiers is important. Companies cannot submit notifications for a group entry, but need to provide a CAS or EC number for their actual substance. An up-to-date list of all substances in Annex I and each group entry can be found on ECHA’s website or through the ePIC tool
Annex I to Regulation (EU) No 649/2012, as amended has three parts listing chemicals that are banned or severely restricted within the EU. Annex I indicates if the chemical use is pesticide and/or industrial chemical. Different provisions apply depending on the part of Annex I.
These chemicals require an active Reference Identification Number (RIN) issued from ePIC before the export or import can proceed.
Exporters and importers must notify yearly exports and imports of these PIC chemicals using ePIC, before 31st March the following year.
To find out if Regulation (EU) No 649/2012, as amended applies to your chemical:
Procedure for Part 1 Chemicals | Procedure for Part 2 Chemicals | Procedure for Part 3 Chemicals | Special RIN Procedure
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Special RIN Procedure
Special Reference Identification Number (RIN) requests for pesticides are dealt with by the Department of Agriculture, Food & the Marine.
Special RIN requests for industrial chemicals are dealt with by the Health & Safety Authority.
Article 2(3) Special RIN (under 10kgs for research/analysis)
Regulation (EU) No 649/2012, as amended shall not apply to chemicals exported for the purpose of research or analysis in quantities that are unlikely to affect human health or the environment and that in any event do not exceed 10 kg from each exporter to each importing country per calendar year. Exporters of the chemicals still need to obtain a special RIN using ePIC and provide that special RIN in their export declaration.
The exporter should
- apply for the Special RIN at least 35 days before the date of export of the chemical
- receive an active Special RIN* if everything is in order
- include the active Special RIN* either in box 44 of the Single Administrative Documents (SAD), or in the corresponding data element in an electronic export declaration
*IMPORTANT ADVICE - An active RIN means a RIN that has customs clearance. Not all RINs are activated. Inactive RINs may be issued automatically.
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