Surprising Enforcement Results – As Many as 19% of Products Fail to Comply with PCN Requirements
On 11 February 2026, the European Chemicals Agency (ECHA) published on its website the results of a pilot enforcement project carried out by the Forum for Exchange of Information on Enforcement. The conclusions are clear: a significant proportion of hazardous mixtures checked had not been notified to poison centres, despite this being a legal requirement.
It is worth noting that the last transitional period (for mixtures notified to national poison centres before the entry into force of Annex VIII to CLP) expired on 1 January 2025 – more than a year ago. Despite this, a considerable number of companies still struggle to recognise or fulfil this obligation.
For both enforcement authorities and companies placing chemical products on the market, this is a clear signal: PCN (Poison Centres Notification) obligations remain an area of elevated regulatory risk and will continue to attract inspection attention.
Scope of Controls – 1,597 Mixtures in 18 Countries
Inspectors in 18 EU/EEA countries checked a total of 1,597 hazardous mixtures to verify compliance with the obligation to submit information to appointed bodies, in accordance with the CLP Regulation.
The objectives of the project were:
- to verify whether companies had submitted the required notification – in as many as 19% of cases, this obligation had not been fulfilled;
- to assess the correctness of labelling (including the presence of the UFI code) – in 15% of cases, the UFI code was missing from the product label;
- to harmonise and strengthen enforcement practices across Member States – the scale of detected non-compliance indicates the need for increased inspection activity in this area.
The names of the companies and product brands inspected during the project were not disclosed. The initiative had a systemic character and was aimed at raising awareness among economic operators.
19% Without Notification – What Does This Mean in Practice?
Under CLP, a company placing on the market a mixture classified as hazardous to human health or for physical hazards is required to submit its composition, as well as other information relevant for emergency health response, to the designated national appointed body.
In practice, this obligation applies to almost all mixtures placed on the EU market that are classified as hazardous to human health (including irritants and sensitisers) or due to their physicochemical properties (e.g. flammable liquids).
Failure to notify means that, in the event of a health emergency, medical personnel may not have access to complete information on the product’s composition. This directly affects the ability to provide effective medical treatment.
As emphasised by the Chair of the project’s working group, missing notifications undermine the effectiveness of the emergency response system. In practical terms, this increases risks to users’ health and may also lead to real administrative and criminal consequences for companies.
15% of Products Without UFI on the Label
The project also revealed that 15% of the inspected mixtures lacked the required UFI (Unique Formula Identifier) on the product label.
The UFI is a 16-character alphanumeric code that:
- uniquely identifies a specific formulation;
- enables poison centres to rapidly link an incident to the relevant composition data;
- constitutes a mandatory labelling element for mixtures subject to PCN notification.
The absence of the UFI on the label – even where notification has been submitted – also constitutes a breach of CLP requirements.
Enforcement Reactions – From Advice to Criminal Sanctions
The range of corrective and enforcement measures applied during the project was broad and included verbal advice, written recommendations, administrative orders (e.g. product withdrawal from the market), financial penalties and, in the most serious cases, criminal complaints. Some cases were still ongoing at the time of publication of the report.
What Does This Mean for Importers and Manufacturers of Chemical Mixtures?
From a practical perspective, two issues are critical:
- Correct identification of the notification obligation and proper submission of the notification;
- Placement of the UFI on the product label (including it only in the Safety Data Sheet will not be considered compliant, except in specific cases).
The absence of either element may be classified as a regulatory breach.
Based on our experience working with importers and manufacturers, the most common reasons for missing notifications include:
- the incorrect assumption that an SDS alone is sufficient to fulfil regulatory obligations;
- lack of awareness that a change in formulation requires a new UFI and an updated notification;
- confusion between C&L notifications and PCN notifications;
- absence of compliance procedures when importing finished mixtures from outside the EU.
The ECHA project demonstrates that, despite several years of application of these rules, the level of compliance remains unsatisfactory.
Conclusions for Companies Placing Mixtures on the EU Market
The pilot project results are more than just statistics – they are a clear indication that supervisory authorities:
- actively verify PCN obligations;
- scrutinise labelling for the presence of UFI;
- apply real enforcement measures ranging from advice to significant penalties.
For companies, this means the need to:
- review their product portfolio in terms of classification;
- verify the notification status of all hazardous mixtures;
- check the correctness of product labelling;
- implement update procedures for any change in formulation.
If you place hazardous mixtures on the EU market and are unsure whether your poison centre notification obligations have been properly fulfilled, a compliance audit is strongly recommended.
In the CLP area, lack of formal compliance very quickly ceases to be a “theoretical risk” – and becomes a real administrative and financial problem.
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