Poison Centre Notifications (PCNs): Common Mistakes That Delay Acceptance

Poison Centre Notifications (PCNs) are a key requirement for companies placing hazardous chemical mixtures on the EU market. The obligation applies to mixtures classified as hazardous to human health or due to physico-chemical properties.  Required under Article 45 of the CLP Regulation, PCNs ensure that emergency health services have the information needed to respond effectively in case of exposure to hazardous mixtures. 

While the obligations are clear, many companies struggle with timely and accurate submission, leading to delays or rejections by national poison centres. Understanding common pitfalls can help organisations streamline compliance and avoid regulatory headaches. 

What Are Poison Centre Notifications?

A PCN provides essential information about a hazardous mixture, including:

• Detailed composition of the mixture 
• Classification in line with the CLP Regulation 
• The Unique Formula Identifier (UFI)Toxicological information 
• Packaging details 
• Product use 

These notifications are submitted via ECHA Submission Portal using a standardised format linked to Unique Formula Identifiers (UFIs), which allow poison centres to quickly identify the exact mixture in case of an emergency call. 

Common Mistakes That Delay Acceptance

Despite clear guidelines, submissions often encounter delays. The most frequent issues include:

1. Incorrect or Missing UFIs
The Unique Formula Identifier is a core element of any PCN. A missing, incorrect, or improperly formatted UFI will typically result in rejection or requests for resubmission.

2. Incomplete Ingredient Information
Providing partial or inconsistent information about hazardous components, concentrations, or CAS numbers can prevent the poison centre from fully assessing the product.

3. Outdated or Inconsistent SDS Data
Poison centres expect data to align with your Safety Data Sheet (SDS). Discrepancies between SDS composition and PCN submissions are a common cause of delays.

4. Misunderstanding Thresholds
Companies sometimes fail to recognise concentration thresholds for hazardous substances that trigger notification requirements. This can result in missing a PCN entirely or submitting it too late.

5. Non-compliance with ECHA Formats
While EU regulations provide a harmonised framework, submission must be made on the ECHA portal. Variations in languages, or units of measurement can delay acceptance.

6. Last-Minute Submissions
Submitting notifications at the last moment without adequate internal review or quality checks increases the likelihood of errors and rejections.

Best Practices for Smooth Submission

To ensure your PCNs are accepted without delay:

1. Verify and Generate Correct UFIs
   Ensure that each mixture has a valid, correctly formatted UFI before submitting.
2. Align SDS and PCN Data
   Cross-check that all hazard classifications, concentrations, and ingredient information match your SDS.
3. Check Regulatory Thresholds
   Review concentration thresholds for hazardous substances and confirm which mixtures require notification.
4. Understand National Portal Requirements
   Familiarise yourself with the technical requirements of each member state portal where you must submit.
5. Plan Ahead
   Prepare submissions well before market introduction to allow time for internal review and corrections.

Why Early Preparation Matters

Proactive management of PCNs not only avoids regulatory delays but also strengthens supply chain confidence and market access. Companies that integrate PCN preparation into product stewardship processes are less likely to face last-minute compliance crises. 

At Penman Consulting, we guide companies through every stage of PCN preparation, from data collection to submission, ensuring that notifications comply with Annex VIII of the CLP Regulation and are accepted the first time.