Q&As

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PIC

PIC Regulation

A. Obligations and processes

Can ECHA or DNAs change the information provided in my export notification or delete my notification?

As an exporter, you are responsible for the content of your export notification, therefore only you can edit the data in a notification. If information is found to be either missing or incorrect, the DNA or ECHA will send the notification back to the exporter for revision.

A fully processed export notification (checked and accepted by both the DNA and ECHA) can no longer be edited or deleted.

Why is my RIN still not active although I notified well in advance of the export?

Export notifications for chemicals listed in part 2 or 3 of Annex I to the PIC Regulation can be activated only if an applicable explicit consent response from the importing country or an accepted waiver proposal is recorded in ePIC.

In the absence of an applicable consent, it is your Designated National Authority's responsibility to make a new request to the importing country.

If 60 days have elapsed since the explicit consent request was registered and there is no response from the importing country, you can propose a standard waiver to activate your RIN. For further information on how to propose waivers though ePIC, see Waiver Information Sheet and ePIC User Manual for Industry.

Why is my RIN not active until the end of the year? Do I need to submit a new notification?

For exports of chemicals listed in part 1 of Annex I of the PIC Regulation, the notification is automatically activated from the expected date of first export until the end of the year, provided that the data requirements are met.

Chemicals listed in parts 2 and 3 of Annex I are additionally subject to the explicit consent procedure. In these cases, the active period of the RIN depends on the availability and on the validity period of the explicit consent response received from the importing country or on the validity period of the accepted waiver proposal.

Further details on RIN statuses can be found in Q&A 1047.

The active period of the existing notification can be extended in case a new consent/waiver with a longer validity period is recorded in the system. There is no need to submit a subsequent notification.

Please contact your Designated National Authority (DNA) if you believe that a new consent from the importing country should be sought.


 

I had submitted a notification with a certain expected amount and I now realise that I will be exporting more than I had originally foreseen. Should I submit a new notification?

There is no need to submit a new export notification. The actual quantities exported are to be provided by the exporter in the annual Article 10 industry report. Similarly, the Article 10 industry report should include a list of names and addresses of each importer to which the shipments took place. Further information on Article 10 can be found in the Article 10 Reporting factsheet.

When should I submit a special RIN request?

A special RIN is a simplified procedure for notifying an export of a PIC chemical. The special RIN request can be applied to the following exports:

  • An Annex I or Annex V chemical for research and analysis purposes, in quantities of 10 kg or less, per year and per importing country, or
  • A chemical listed in Annex I part 3 for which a positive import decision is available in the latest PIC Circular, or
  • The importing country has waived its right to receive an export notification for this/all chemical(s).

Special RIN requests are managed by the National Designated Authorities (DNAs) and ECHA is not involved in this process.

Further information on special RIN requests can be found in “Special RIN Requests” factsheet.

B. Article 10 reporting

Shall I use ePIC to fulfil my reporting obligations under Article 10?

Yes, ePIC provides the industry with a user interface to report exports and imports of chemicals subject to the PIC Regulation that took place during the previous calendar year, and by that fulfil their obligations under the Article 10 of that regulation. The report for exports is pre-filled from the export notifications – to the extent possible - by ePIC when the data is available in the system.


When and how should I report the exact quantities of PIC chemicals exported and imported during the previous calendar year?

You should submit the information concerning exports and imports of PIC chemicals that took place during the previous calendar year to your designated national authority (DNA) during the first quarter of each year. The information should be provided by using ePIC’s ‘Article 10 reports’ functionality.

Export of PIC chemicals

On 1 January of each year, ePIC automatically pre-generates a draft report for the previous year's exports, as long as there is at least one validated export notification in the system for the reporting period.

You should finalise the report and submit it to your DNA in ePIC, by 31 March at the latest each year.

Import of PIC chemicals

Unlike for exports, the report on imports are not pre-generated. Therefore, you should always create and fill the report manually by using the functionality ‘Create report on imports’ available in ePIC. You should finalise the report and submit it to your DNA in ePIC, by 31 March at the latest each year.

Detailed information on how to submit article 10 reports can be found in the ePIC User Manual for Industry.

I did not submit any export notifications last year but I would still like to report on the quantities of PIC chemicals that I exported. How should I do it?

It is a legal obligation for you to submit an export notification before exporting a chemical that is subject to the PIC Regulation.

If, however, you exported PIC chemicals during the previous calendar year without submitting an export notification, you can still comply with your reporting obligation by manually creating a report using the "Create report on exports" feature.

I have already submitted my report but now realise that some corrections are needed. How shall I proceed?

If there is a need to introduce changes to an already submitted report, you should first contact your designated national authority (DNA) outside the ePIC application. Your DNA can then send the report back to you in ePIC, where you can make the necessary corrections and resubmit.

 

Please find further information in Chapter 12.4.2 “Resubmission of Article 10 reports” of the ePIC Use Manual for Industry.

I cannot create a report, as the system says that ‘a report is already available’. What shall I do?

ePIC automatically pre-generates a draft report for reporting exports, if the exporter had at least one export notification submitted and validated through ePIC during the year to be reported on. Once there is a pre-generated report in the system, you are not be able to create another report manually, and you should use the pre-generated report.

The pre-generated report can be easily accessed from the homepage:

I have never used ePIC since I am not an exporter of PIC chemicals. How should I report on imports of PIC chemicals?

You have two options:

  • The preferred option is that you create an account in ePIC and prepare your report on imports with the dedicated functionality ‘Create report on imports’. To create an account in ePIC, please refer to QA 956.

  • Alternatively, you may contact your designated national authority (DNA) and ask them whether you can provide the relevant information to them outside the system. If they agree, they can create reports based on the information received from the importer.

An export for which I had submitted an export notification did not take place. How can I delete in ePIC the related Article 10 pre-generated report or the related specific row in the pre-generated report?

You are not able to delete either the pre-generated report as a whole or any RIN-specific record in it. If the export did not take place, please report a zero (0) quantity for that export.

C. PIC Information disseminated by ECHA

What information related to PIC is disseminated on the ECHA website?

ECHA is making publicly available the information on chemicals listed in the relevant annexes of the PIC Regulation that are exported from and imported to the European Union: http://echa.europa.eu/information-on-chemicals/pic/chemicals

The following data will be made publicly available from individual exporters submitting export notifications under the PIC Regulation:

1.For export notifications:

  • The year of the export;
  • The exporting EU Member State;
  • The importing country;
  • The non-confidential identity of the chemical or mixture or article exported (as provided by the exporter);
  • Its type (chemical, mixture or article).

2. For explicit consents:

  • The non-confidential identity of the chemical, mixture or article (as provided by the exporter) for which a consent is sought;
  • Its type (chemical, mixture or article);
  • The use category for which consent is sought;
  • The importing country;
  • The exporting EU Member State;
  • Whether a consent is sought;
  • The request date;
  • The validity start date (if applicable);
  • The validity expiry date (if applicable)
  • The status of the consent (Pending, Accepted, Rejected, Closed).
ePIC

A. Log in to ePIC and account management

How do I access ePIC?

All PIC related activities should be carried out using the ePIC portal. If you are new to ePIC, you need to register a company before you can log in.

If you already have a valid account created in REACH-IT or you use a REACH-IT account for REACH or CLP purposes, refer to the ECHA Accounts Q&As and ECHA Accounts Manual.

I try to log in to ePIC and I receive a message indicating that “no role or company details have been provided”. What shall I do?

You need an ePIC role in ‘ECHA Accounts’ before you gain access to the ePIC application.

If you have signed up in ‘ECHA Accounts’ from 2 September 2014, you may also receive this message, if no legal entity details have been provided. If this applies to you, log in to ECHA Accounts, encode your legal entity and include a contact person before you log in to ePIC.

I can access ePIC but I am not able to create any notifications. What should I do?

You may have a “read-only” access to ePIC. You should contact your Legal Entity Manager within your company to verify your ePIC role.

The following roles are available in the system:

For account management: Legal Entity Manager - can modify the legal entity data, contact data and user data.

  • Access to ECHA application (ePIC in this case):

  • Manager: full access

  • Reader: read-only access

Please find further information on the ECHA Accounts Q&As and ECHA Accounts Manual.

My company has changed name and we have valid notifications under the old name of the company. Do we need to send new notifications with the new company name?
A company can change its legal entity name in “ECHA accounts”. The name change will have the following consequences:
  • The PDF templates for the already submitted export notifications will not be impacted by the change: they will still have the ‘old’ name in the exporter details section.
  • The name change will take immediate effect in the customs application, e.g. when customs checks the current RINs, the new legal entity name will be displayed.
Therefore, in case of name change of the exporting company, there is no need to submit new notifications for exports that have already been notified.
Can a legal entity be created after a successful merger of two companies use the export notifications submitted by one of the companies before the merger?
The PIC Regulation does not describe a so-called “legal entity change” and therefore no such functionality is available within the ePIC submission tool. It is not possible to transfer assets (export notifications, special RIN request etc.) from one account to another in ePIC. To continue exporting, the legal successor will need to submit new notifications.
B. Functionalities of ePIC

Which functionalities are available to exporters in ePIC?

The ePIC industry interface enables exporters and importers of PIC chemicals to submit data to and exchange information with authorities in a secure way. More specifically, through this interface industry users can submit:

  • export notifications,

  • special RIN requests,

  • waiver proposals,

  • exports and/or imports reports.

Industry users can also follow in ePIC the progress of the processing and status of their submissions.

How can I submit a waiver proposal?

A waiver proposal can be submitted in ePIC from the notification form using the ‘Propose waiver’ functionality.

 

More information can be found in ‘Waiver information sheet.

I created an export notification for a mixture but I did not manage to attach a Safety Data Sheet (SDS). How can I do this?

In case the export notification concerns a mixture, the “Attachments” section of the notification form displays automatically all SDS files that are associated to the selected mixture.

 

If no SDS is displayed in the “Attachments” section, you need to go back to your mixture master data (using “Manage mixtures” functionality in ePIC) and upload the SDS file(s) before (re)submitting your notification. Once the SDS file(s) are attached to your mixture and you have saved the record, the uploaded document(s) will be automatically displayed in the export notification form. If you have attached several language versions of the SDS, you may choose the relevant one(s) by selecting the checkboxes in the “Action” column.

 

Note that you should not use the options "Other" or "Emergency" for uploading SDS files.

I have received an e-mail stating that "Information requirements are not met", but with no further information. How can I find out which information requirements are not met?

The reason why your notification has been sent back to you can be consulted in ePIC, in the “Message history” section.

You can access the message history of a notification by clicking on the link you received in the automated e-mail. Alternatively, you can view messages by doing the following:

1.Log in to ePIC if necessary

2.Search for the RIN

3.Go to View menu (see image)

4.Select "Message history"

5.Click in the arrow Arrow next to the message to open it. You can consult the details there.

If you need additional clarification you can contact your DNA directly.
The contact details for the designated national authorities

What are the statuses of an export notification in ePIC?

The ePIC application shows the status of a RIN at the present moment in time. The possible statuses are: "Inactive", "Active", "Disabled" or "Expired".

"Inactive" means that the export cannot take place yet.

Inactive

"Inactive" without the validity period in brackets: The RIN has not been activated yet. The export cannot take place unless an appropriate explicit consent/waiver has been registered in the system.

"Inactive" with the validity period in brackets means that the notification has been activated, but the export will happen in the future. For example, a RIN status such as the following "Inactive (19/07/2017 – 25/10/2017)” tells you that:

  • The RIN is inactive today

  • The RIN shall be active from 19 July 2017 until 25 October 2017; and

  • The RIN activation is linked to a consent/waiver whose validity ends on 25 October 2017

The status "Active" with the validity period in brackets means that the export can take place at present. The validity period of the RIN is indicated in brackets.

 

 Disabled

"Disabled" means that the export notification has been either rejected or disabled due to a negative explicit consent response. 

 

The status "Expired" means that the export notification refers to previous years' exports.

I am trying to prepare an export notification for a group entry, but the system displays an error message. What shall I do?

It is not possible to create an export notification for a chemical by selecting the generic group entry only. You must specify either the CAS number or the EC number (when available) of the specific substance you intend to export.

How do I attach more than one language version of the SDS in my notification?

In case the export notification concerns a chemical, you can upload several language versions of the SDS in the “Attachments” section of the export notification form. You should not use document types “Other” or “Emergency”.

 

In case the export concerns a mixture, the different language versions can be added using the “Manage mixture” functionality. Once the safety data sheet is attached to your mixture and you have saved the record, the uploaded document(s) will be automatically displayed in the “Attachments” section of the export notification form. If several language versions are attached to your notification, you should choose the relevant one(s) by selecting the checkboxes in the “Action” column.

I am trying to enter a CAS number in ePIC but the system does not recognise it. Does this mean that the substance is not subject to the PIC Regulation?

No. It should be understood that the lists of substances under group entries in ePIC are not fully comprehensive and new entries can be added on a case-by-case basis.

From a legal perspective, when a group entry is subject to the provisions of the PIC Regulation, all the substances under that entry are covered irrespective whether the  specific substance identifiers (e.g. CAS or EC numbers) is already included under the group entry in ePIC or not.

If you are exporting a substance that you believe belongs to this group but cannot find it in ePIC, you should contact the ECHA Helpdesk.

ECHA then verifies the entry and adds the substance under the relevant group in ePIC if needed.

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