Q&As

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The UKs withdrawal from the EU

PIC

After the UK withdrawal, will my EU-27-based company need to notify an export of a chemical subject to the PIC Regulation to the UK?

Yes. The EU PIC Regulation places obligations on companies based in the EU who wish to export chemicals listed in Annex I to non-EU countries. As the UK will no longer be a Member State of the EU, any such exports will need to be notified.

See also QA1568.

After the UK withdrawal, will my EU-27-based company need to notify an export of a chemical subject to the Rotterdam Convention (and therefore also to the PIC Regulation) to the UK?

The UK is itself a Party to the Rotterdam Convention. Therefore, if you are planning to export a chemical listed in Annex III to the Rotterdam Convention to the UK, you must check in the latest PIC Circular whether the UK has provided an import response. In case there is a positive response, it will be sufficient to submit a special RIN request (please see the factsheet); in the absence of a response, you must submit an export notification, and an explicit consent from the authorities in the UK will be required in order for the export to take place.

After the UK withdrawal, will my EU-27-based company need to notify an export of a chemical subject to the PIC Regulation to Gibraltar?

As Gibraltar is currently (i.e., even prior to the UK withdrawal) not a part of the EU customs territory, you will simply need to continue notifying your exports of chemicals subject to the PIC Regulation also after the UK withdrawal.

My EU-27-based company buys a product from a company based in the UK and it is subsequently shipped directly to my customer who is based in another non-EU country. Do we need to notify the export?

Even though you hold the contract for this export, in this case, in accordance with Article 3(18)(b) of the PIC Regulation, the UK company currently takes on the role of the exporter. After the UK withdrawal, the UK company will no longer have any obligations under the EU PIC Regulation. Consequently, no export notification will be needed.

However, please note that the following circumstances may lead to exceptions:

  • Any national legislation regulating exports in place in the UK;
  • If the exported chemical is listed in Annex III to the Rotterdam Convention (as well as being subject to the EU PIC Regulation).
My EU-27-based company imports chemicals subject to PIC from companies based in the UK. Will we have any additional obligations after the UK withdrawal?

Yes, pursuant to Article 10(1) of the PIC Regulation, in the first quarter of the year following the import you should provide details on the import(s) to your Designated National Authority (DNA) by means of ePIC (https://echa.europa.eu/support/dossier-submission-tools/epic).

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