ECHA Pilot Project Reveals Persistent Gaps in PCN Compliance
The European Chemicals Agency (ECHA) has published the initial results of its Forum Pilot Project on the Enforcement of Poison Centre Notifications (PCNs), providing the clearest picture to date of how well companies are meeting their obligations under Article 45 and Annex VIII of the CLP Regulation. The findings show that significant gaps remain in both PCN submissions and safety documentation compliance across the EU.
Implications for Industry
On the 1st January 2025 it became mandatory for a PCN submission to be made for hazardous chemicals and mixtures sold in the EU. For the first six months of 2025, ECHA ran an enforcement project focussed on PCN compliance via a combination of on-site and remote checks . Released in February 2026, the findings from the project clearly show that a significant proportion of duty holders are still not meeting core requirements around PCN submissions, UFI placement and consistency of safety documentation such as SDS and labels. This lack of compliance directly undermines the ability of poison centres to provide effective emergency health responses.
Key Findings
Non-submission of PCNs – across 1,597 mixtures inspected, 19% of mixtures requiring a PCN had no notification submitted.
UFI Presence – every mandatory PNC must have an associated UFI, however it was found that of the inspected mixtures, UFIs were missing from:
- 15% of labels
- 25% of SDSs
However, where a UFI was used, it was correctly placed on the label in 97% of mixtures.
Inconsistencies Between Documentation – Information should be consistent between all forms of documentation (PCN, SDS, label etc), however, PCNs had been submitted:
- 17% were inconsistent with the SDS (most often mixture components and toxicological information).
- 13% were inconsistent with the product label (primarily in labelling elements, trade name or volume).
These inconsistencies suggest that updates to labels, SDSs and notification dossiers are not always carried out in parallel.
Company size – The project also highlighted that compliance levels were similar between SMEs (59%) and large companies (58%), indicating that compliance issues are widespread regardless of company size.
What should I do next?
Based on the findings and the recommendations in the report, and to avoid enforcement action, companies placing hazardous mixtures on the EU market might need to consider actions including:
- Review all PCN submissions- Ensure PCNs have been submitted for all relevant mixtures and contain complete, harmonised information.
- UFI-wherever required, ensure that a UFI is present, it is correctly structured and it appears consistently on the label, in the SDS (where applicable) and in the PCN.
- Consistency of PCN, SDS and label information – Align mixture composition, hazard classification, trade names and volumes across all documents to avoid inconsistencies.
Act Now to Strengthen Compliance
ECHA’s report demonstrates that PCN non-compliance is common and that enforcement measures are increasing. Companies should ensure their internal processes, documentation systems and supplier arrangements fully align with CLP and Annex VIII requirements.
If your organisation needs support reviewing your PCN obligations, UFI implementation or documentation consistency – get in touch!