EU PIC amendment takes effect: Over 30 chemical substances added to control, export of 3 POPs banned

The PIC Regulation is the core regulation of the EU to implement the Rotterdam Convention, and establishes three types of manage mechanisms to international trade in hazardous chemicals and pesticides: export notification, prior informed consent (PIC), and export bans. Among them, Annex I mainly manages the export notification and prior informed consent procedures, while Annex V lists the chemicals subject to export bans, and the two lists apply different regulatory rules.

This revision adds three persistent organic contaminants (POPs) to Annex V: UV-328, Dechlorane Plus, and Methoxychlor, and basically prohibits the export of these substances from the EU to other countries.

The new regulation also sets exemption clauses: UV-328 and Dechlorane Plus can be exempt from the export ban if they meet the specific exemption conditions or levels limit standards of the EU POPs Regulation; Methoxychlor also has supporting exemption provisions related to levels limits.

The Annex I list has been greatly expanded. The first part adds 36 chemicals covering manufacturing chemicals, ultraviolet absorbers, pesticides and other categories, including manufacturing raw materials such as DEHP, DBP, trichloroethylene, arsenic trioxide, arsenic acid, chromic anhydride, some chromium compounds, MOCA, UV-320, UV-327, UV-350, as well as pesticides and fungicides such as carbendazim, dodecylguanidine acetate, pyraclostrobin, PHMB, DOTE/MOTE interaction mixture, and triflusulfuron-methyl.

The second part of Annex I adds 17 substances, most of which are manufacturing chemicals and pesticides that are also included in the first part of Annex I. Unlike the first part which only requires export notification, substances classified in this part need to go through a stricter prior informed consent procedure when exported. Many newly added substances have been included in the EU REACH and CLP regulations to manage before, and after being included in the PIC list this time, they will be superimposed with cross-border trade supervision obligations at the export end.

Relying on the resolution of the 12th Conference of the Parties to the Rotterdam Convention in 2025, specific ultra-low volume formulations of two pesticides, carbosulfan and fenthion, have been included in the PIC procedure, and the listing status of carbosulfan in Annex I has also been adjusted simultaneously. In addition, this revision also updates the information of some existing substances, and the CN code of the mixture related to terbufos has been adjusted from ex 3808.59 to ex 3808.91.

sector analysis pointed out that this revision covers high-risk substances such as manufacturing chemicals and pesticides. On the one hand, it adds regulation objects to export notification and prior informed consent, and on the other hand, it expands the scope of substances subject to export ban supervision, which marks that the EU's supervision on chemical exports continues to tighten.

Relevant foreign trade companies need to check their product lists in time, complete export notification and prior informed consent declarations, focus on verifying the exemption conditions to POPs substances, and prevent export compliance risks.