ECHA Releases Pilot Project Report on PCN Enforcement: Nearly 20% of Companies Failed to Meet Compliance Obligations

In February 2026, the European Chemicals Agency (ECHA) published the Pilot Project Report on Poison Centre Notification (PCN) Enforcement. The report reveals that, among the 1,597 mixtures inspected in the first half of 2025, 19% of companies had not submitted the required PCNs to poison centres, and 15% of product labels lacked the crucial Unique Formula Identifier (UFI).

Background 

According to Article 45 of the CLP Regulation, EU importers and downstream users placing hazardous mixtures (posing physical or health hazards) on the market must submit 100% of the mixture's components and other necessary information to the poison centres. Non-EU suppliers aiming to protect business secrets can also appoint a legal entity within the EU to submit a voluntary notification; in such cases, providing only a UFI number is sufficient to keep component information confidential.

Participation Details

• Participating Countries: 18 countries (nearly two-thirds of EU/EEA countries)
• Total Inspections: 1,597 mixtures
• Inspection Methods: On-site checks (28%), desktop checks (32%), combined methods (41%)
• Product Types: Consumer products (83%), professional use products (39%), industrial use products (18%)

Key Findings

Major Non-Compliance Issues

1. Failure to submit PCN (19%) – Most common issue
2. Inconsistency between PCN and SDS information (17%) – Primarily concerning mixture composition and toxicity information
3. Inconsistency between PCN and label information (13%) – Mainly related to label elements, trade names, volume
4. Missing UFI on the label (15%)
5. Missing UFI on the SDS (25%, where required)
6. Use of the same UFI for different formulations (approx. 1%)

Responsible Party Analysis

• Highest PCN Submitters: Downstream users (44%), Importers (19%)
• Highest Non-Submitters of PCN: Downstream users (28%), Distributors (23%), Importers (19%)

Enforcement Measures

• Written Advice: 68%
• Verbal Advice: 15%
• Administrative Orders: 11%
• Fines: 5%
• Criminal Complaints: 4%

Recommended Future Actions 

ECHA provided specific recommendations to relevant parties:

• European Commission: Amend CLP Regulation Article 45 to grant enforcement authorities direct access to national PCN data.
• Member States: Establish national procedures allowing enforcement agencies to access relevant data while ensuring confidentiality.
• Industry Associations: Strengthen awareness campaigns regarding UFI and notification requirements, informing businesses that the transition period ended in January 2025.
• Consumers: Learn to identify labels on hazardous mixtures and understand the importance of the UFI.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

ECHA