Annex VIII to CLP inadvertently brought into UK law

Annex VIII to CLP Retained in the UK

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Thanks to Steven Marks of Airedale Chemical, we broke the news that Annex VIII to CLP had been inadvertently retained in UK law (not just once, but in 3 separate places).

Earlier in the year, the Department of Health and Social Care, who are responsible for PCN in the UK, announced that there would be a 12 week public consultation period on whether Annex VIII should be removed from UK law, or retained.  At the time of writing, November 2022, there is no sign of this starting, although there has been a certain amount of political turmoil (3 Prime Ministers, 2 Monarchs, ministerial reshuffles etc).

There is currently conflict between the advice on the website, which refers to the “old” system of sending SDSs to NPIS on a voluntary basis, and the fact that legally we should be compliant with Annex VIII, that is using a UFI on the label, and providing all of the information required as per the EU portal.

The most important thing is don’t panic – there are options around this, and you don’t want to take an action which may be expensive (in terms of time and workload) which may not turn out to be necessary.

  • if you have notified to NPIS for Northern Ireland, by sending them an IUCLID6 PCN file, that is deemed to be notified to the UK under Annex VIII already
  • if you have sent in SDSs voluntarily, you have notified these mixtures under the old system

For more advice and practical tips on what your options are, see

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