40 Hazardous Chemicals Added to EU Export List Under the PIC Regulation

Dr Steven Brennan
Dr Steven Brennan
2 min readAI-drafted, expert reviewed
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Key takeaway

What this development means

The European Commission has updated the EU’s Prior Informed Consent (PIC) Regulation, adding 40 hazardous chemicals to its Annex I, effective 1 March 2025. This amendment requires exporters to notify ECHA before exporting these substances, with 38 also requiring explicit consent from importing countries. The update includes 35 pesticides, five industrial chemicals, and changes to the export requirements for cyanamide and warfarin. Additionally, PFHxS and related compounds are now subject to a complete export ban under Annex V, aligning EU regulations with international conventions to strengthen protections for human health and the environment.

Why were 40 new chemicals added to the PIC Regulation?

These chemicals, including 35 pesticides and five industrial chemicals, were added to protect human health and the environment. Many of them are now banned or severely restricted within the EU, prompting the need for stricter control over their export and alignment with international agreements like the Rotterdam Convention.

What are the implications of adding PFHxS to the export ban list?

PFHxS, its salts, and related compounds are listed as persistent organic pollutants under the Stockholm Convention. Their inclusion in Annex V of the PIC Regulation means they are entirely banned from export, reflecting their significant environmental and health risks.

Source basis: https://echa.europa.eu/-/40-hazardous-chemicals-added-to-pic-exporters-can-start-notifying-authorities-now

The European Chemicals Agency (ECHA) has announced the addition of 40 hazardous chemicals to Annex I of the Prior Informed Consent (PIC) Regulation, effective 1 March 2025. This update mandates EU exporters to notify authorities and, in most cases, obtain explicit consent from importing countries before exportation.

The newly listed substances include 35 pesticides such as abamectin, difenacoum, and fenpropimorph, along with five industrial chemicals. Additionally, the status of cyanamide and warfarin has been upgraded to require explicit consent, while perfluorohexane sulfonic acid (PFHxS) and its related compounds have been added to Annex V, imposing a complete export ban.

What Is the PIC Regulation?

The PIC Regulation, in line with the Rotterdam Convention, governs the export and import of chemicals banned or heavily restricted in the EU. Its purpose is to protect human health and the environment while promoting informed decision-making in global trade.

Implications for Exporters

EU-based companies intending to export these substances must use ECHA’s ePIC IT system for notifications. Explicit consent requirements apply to 38 of the newly added chemicals, underscoring the need for transparency and compliance with international agreements.

Key Updates at a Glance

Substances Requiring Explicit Consent: Cyanamide, warfarin, and others already listed in Annex I now demand consent from importing nations.New Export Ban: PFHxS and related compounds, listed as persistent organic pollutants, are entirely prohibited for export.Annex I Expansion: The total number of chemicals in Annex I now stands at 321 entries.

Background

The European Commission annually updates the PIC Regulation to reflect changes in EU legislation and international treaties. The latest revision includes chemicals withdrawn from approval processes under the EU’s REACH and biocidal product regulations due to environmental or health concerns​​.

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