EU Commission Plans Significant Expansion of the PIC Regulation for Hazardous Substances

The European Commission has proposed a comprehensive update to EU regulations governing the import and export of hazardous chemicals. With the planned revision of the PIC (Prior Informed Consent) Regulation, numerous additional substances will be subject to the European Union’s strict export and reporting requirements for the first time.

Expansion of Substance Lists in Line with Recent Regulatory Developments

With a draft delegated regulation published on 9 June 2026, the European Commission intends to amend Annexes I and V of the PIC Regulation. The proposal is primarily driven by recent regulatory developments under the REACH Regulation, the Biocidal Products Regulation, and the Stockholm Convention on Persistent Organic Pollutants (POPs). The objective of the revision is to align the existing framework with current scientific knowledge and regulatory restrictions already in force within the EU. The proposed amendments are scheduled to apply from 1 October 2026.

The PIC Regulation is designed to control international trade in chemicals whose use within the European Union is prohibited or severely restricted. Companies wishing to export such substances to non-EU countries must comply with specific information and notification requirements. For particularly hazardous substances, the explicit consent of the importing country is required before exports can take place. This mechanism ensures that third countries are informed about the potential risks associated with the chemicals concerned and can independently decide whether to permit their import.

Numerous CMR and SVHC Substances to Become Subject to New Obligations

A key element of the proposed amendment is the inclusion of numerous additional substances in Annex I of the PIC Regulation. In particular, the proposal targets carcinogenic, mutagenic, and reprotoxic (CMR) substances whose supply to consumers is already restricted within the EU. These include, among others, the phthalates DEHP and DBP, trichloroethylene, and various chromium and arsenic compounds. Once listed in the Annex, these substances would become subject to specific export notification and authorization requirements.

In addition, several substances of very high concern (SVHCs) that are already subject to the REACH authorization regime are proposed for inclusion in the PIC framework. Examples include the UV absorbers UV-327, UV-350, and UV-320, as well as various industrial additives and organotin compounds. Through these measures, the Commission aims to increase transparency and strengthen control over international trade in substances that are already subject to stricter regulation within the EU due to their hazardous properties.

Export Bans and Potential Implications for Businesses

The draft regulation also proposes adding UV-328 and Dechlorane Plus to Annex V of the PIC Regulation. Annex V covers chemicals that are subject to an export ban. Their proposed inclusion is linked to their listing under the Stockholm Convention and the subsequent implementation of these restrictions through the EU POPs Regulation. As a result, the export of these substances from the European Union would generally be prohibited.

The draft is now under review by the European Parliament and the Council. If no objections are raised during the prescribed scrutiny period, the regulation may enter into force following its publication in the Official Journal of the European Union, significantly tightening the requirements governing international trade in chemicals within the EU.

We provide comprehensive support regarding compliance with the PIC Regulation, including impact assessments and regulatory monitoring services