Poison Centre Notification is required under CLP, Article 45, where you need to notify mixtures with physical or health hazards to the Poison Centres in each EU Member State you’re selling the mixture into.
The exception is the UK, which has decided that this is a voluntary notification, but everybody else interprets it as a mandatory requirement.
The good news is that we have some movement on the Poison Centre Notification Portal, which opened for business at ECHA on the 24th April, here https://poisoncentres.echa.europa.eu/echa-submission-portal .
This Portal will allow companies inside the EU to notify all the Poison Centres in individual Member States at once, removing the need to notify multiple times to each Poison Centre separately.
The bad news is that although the Portal is up and running, we have just heard that not one single Member State is able to receive the data yet!
So at the moment, the Portal is only any good for practicing your submissions, rather than actually making them, although if you are using it, please make sure you are doing it for actual products, in case it suddenly goes live (you don’t want to have a fake formulation suddenly being sent to every Poison Centre!).
There is even a rumour that the deadline for making these submissions may be pushed back by 6 months to 1 year, because of the lack of preparation at the Member States.
So, what can you do if you’re required to notify the Poison Centres about your hazardous mixture?
The best thing is to manually notify each individual Poison Centre where you sell the mixture. This will keep you compliant, and also allow you to take advantage of the phase-in timescale.
The phase-in timescale allows you to delay Poison Centre notification using the Portal until 1st January 2025, if you notify to a relevant Poison Centre using their current system before the “date of applicability” listed below, depending on which market your mixture is sold into:
- Consumer use mixtures – 1st January 2020
- Professional use mixtures – 1st January 2021
- Industrial mixtures – 1st January 2024
If you are notifying manually, the only thing to watch out for is that you can’t have the U.F.I (Unique Formulation Identifier) on the mixture or package, because it’s only applicable to mixtures which have been notified via the Portal.
Of course, the situation is even more complicated for UK companies, as they may not be able to notify via the Portal, depending on when, or if, Brexit happens! But that’s a topic for another day.
GHS Classification Courses from TT Environmental Ltd
25th June 2019
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