The Poison Centre transition period has ended - what next?

Annex VIII to CLP sets out deadlines by which notifications in the new harmonised format must have been completed via the European Chemicals Agency (ECHA) notification portal. The compliance dates for ‘Consumer or Professional’ and ‘Industrial’ use products have now passed. 

The final compliance date of the 1st January 2025 applies to any remaining notifications previously notified through Member State national systems and still benefiting from the transition period. These notifications will be required to comply with Annex VIII of CLP by the final compliance date, 1st January 2025.

Businesses must ensure their remaining notifications for any mixture classified as hazardous are completed via the ECHA notification portal, and that a Unique Formula Identifier (UFI) has been generated for their product(s) and added to labels and SDS as required.

What can you expect after the transition period is over?

Once notifications have been completed, there are three key focus points for businesses:

• Enforcement
• Maintaining compliance
• Divergence between the EU and the UK

Enforcement

ECHA’s Enforcement Forum announced in early 2024 that it is preparing an enforcement project to check if suppliers have notified hazardous chemical mixtures to Poison Centres in accordance with Annex VIII to CLP. In June 2024 ECHA’s Enforcement Forum also agreed to a new EU-wide project to check that hazardous mixtures present in products such as air fresheners or electronic cigarettes, are classified, labelled, and packaged correctly to protect consumers and children from chemical hazards.

The REF-14 project will be prepared in 2025 and inspections are expected in 2026, where checks will establish if suppliers are fulfilling their duties under the CLP regulation, including:

• Classification and labelling
• Packaging and child resistant fastening
• Poison Centre Notifications
• Safety data sheets of the mixtures

Maintaining compliance

Ensuring Poison Centre notifications for your products are up to date is a crucial part of maintaining your market access, protecting your reputation with customers and key stakeholders within each Member State and streamlining the movement of your goods.

If you change any of the following aspects of your product you are required to update your Poison Centre Notification:

• Change in composition.
• Change in market placement.
• Change in hazard classification of the overall product.
• Change in trade name.
• Change in legal entity details.

Divergence between the EU and the UK

Poison Centre Notifications are not the only aspect of CLP to be impacted by divergence between the EU and the UK, as currently there are different Poison Centre requirements in Great Britain and Northern Ireland. In addition to this, divergences are appearing with regards to CLP mandatory classifications, Safety Data Sheets and REACH.

As we move further beyond Brexit the impact of regulatory divergence on businesses will require increasingly  differing approaches to placing mixtures on the market in the EU to the UK.

Solutions for your business

Ricardo’s team of chemical regulatory and compliance experts can support your organisation with completing your Poison Centre Notifications for your hazardous mixtures ahead of the transition period deadline, allowing you to achieve compliance.

Once achieved, it can be challenging for businesses to maintain compliance. Ricardo offers several solutions to support businesses with Poison Centre Notification and other chemicals compliance challenges, including:

• Poison Centre Notification and SDS Authoring Service - Outsource your Poison Centre Notifications and SDS Authoring to our expert team, providing you peace of mind and time to focus on other aspects. Learn more >
• Chemical Compliance Monitor - Receive a bi-annual report tailored to your substance portfolio, providing an overview of which substances in your portfolio are subject to regulatory scrutiny and require potential future action. Learn more >
• Training - Expert-led and tailored training supports your team to develop an understanding of the regulatory requirements of using chemicals in the workplace and how to interpret complex regulations in a practical context. Learn more >
• Reports - Providing in-depth information regarding regulations such as the Biocidal Product Regulations and Poison Centre Compliance in the EU and many more to assist your organisation to interpret the risks and challenges facing your product portfolio. Learn more >

Learn more about our solutions for the chemical sector >