As part of Annex VIII to CLP, you are required to complete poison centre notifications. Unless you do your notifications via member states, you need to have completed your notifications through the new harmonised portal and comply to the other requirements such as product categorisation and UFIs (unique formulation numbers) on packaging of products classified as hazardous to human health or physical classifications. By completing your notifications via member states you can make use of the transitional period till 2025.
Industry have been lobbying for an amendment to Annex VIII and the amendment was discussed at CARACL, where there were no major objections. The amendment will provide an extension to the consumer use deadline for notifying via the European Chemicals Agency (ECHA) portal to 2021, which means, the deadline would then move from 1st January 2020 to 1st January 2021 (same as the professional use products deadline). Until this legislation has been passed the industry should be preparing for Annex VIII and the deadlines as they stand;
Consumer use – 1st January 2020
Professional use – 1st January 2021
Industrial use – 1st January 2024
Those who have completed Member State notifications – 1st January 2025
As previously mentioned UFI numbers will be required on packaging. These numbers were supposed to be uncrackable, therefore toll manufacturers could be completing a single notification for multiple customers if the product is the same. However, it has come to NCEC’s attention that there are now websites that will uncode the UFI. To create a UFI, an internal number along with a VAT number, must be submitted. The uncoder will provide you with the notifiers VAT number, which is a publicly known number that will lead people to identifying the manufacturer. ECHA are yet to respond to this, however in general, this won’t be an issue for industry apart from the exception discussed.
NCEC still believes that the best way to notify and stay ahead of the legislation is to notify now via Member States.
But why should you notify now?
Because notifying now would not only help you avoid some of the more difficult Annex VIII requirements but also benefit your business in terms of cost effectiveness and legal compliance.
Please contact us now to find out how NCEC can help you with your notifications.
Information is true as of 16:00, 5 August 2019.