If your company has notified hazardous chemical mixtures directly to the National Poisons Information Centre of Ireland (NPIC) and you intend to keep placing the same mixtures on the market after 1 January 2025, you must submit a new notification in accordance with Annex VIII, via the ECHA PCN portal, and include the UFI on the label by that date.

Annex VIII to the CLP Regulation defines the harmonised requirements for poison centre notifications (PCN). ECHA has established a harmonised PCN format for submitting the required information to poison centres and a submission portal for industry to prepare and submit information according to the harmonised format.

If your product remains on the market until 1 January 2025 and is unchanged, you must make a new submission in the harmonised format via the PCN portal, as no migration of data from the NPIC database is planned. However, if there is a change in the mixture composition, product identifier or toxicological properties (as indicated in Part B, Section 4.1 of Annex VIII) during the transitional period before 1 January 2025, the duty holder is required to submit information concerning the changed mixture in accordance with Annex VIII before it is placed on the market. If your product is discontinued before the end of 2024, you do not need to make a new submission.

As of 1 January 2025, ‘old’ submissions sent directly to the NPIC will be considered ‘archived’ and not complaint with regard to Annex VIII. Thus, you must ensure that a new, Annex VIII compliant submission is made, and product labels are updated, in time to allow you to continue placing the mixture on the market after this date.

Please note also that the NPIC charges an annual retainer for use of it’s telephone number on the SDS of chemical products placed on the market in Ireland. The annual retainer is €650 per company (or €200 if notifying less than 10 products).

Further information on the procedure to follow can be found at https://poisons.ie/industry-manufacturers/safety-data-sheets/