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Frequently asked questions

How do I get a RIN?

A RIN is a reference identification number. To get one, you need to electronically submit an export notification in the EDEXIM database. To do this you need an on-line notification account

If you export chemicals in quantities of 10 kg or less per annum for research or analysis you need a reference identification number (RIN) even though the export is exempt from export notification.

How can I notify on-line?

Request an on-line notification account by e-mailing UKDNA@hse.gov.uk with the subject line 'Edexim Account Request'. Then follow the guidance on Completing an export notification on-line using EDEXIM database.

I export a number of chemicals, are these covered by the regulations?

Under the regulations all exports of chemicals must be packaged and labelled to at least the same standards as those for sale within the European Community. However, only those chemicals listed in Annex I of Regulation (EU) 649/2012 are subject to the export notification and possibly explicit consent procedures. For clarification of the tiers your chemicals may be subject to, go to the main requirements of the regulation. Then check to see whether the chemicals are restricted or banned in the EU by following our guidance on How to identify restricted or banned exports - step by step.

What about preparations?

If the preparation contains a substance that is listed on Annex I and present in a concentration that attracts classification (for health or environmental effects) then it is covered by the requirements of the regulation.

I export a small quantity, do I need to notify?

If the amount to be exported is less than 10kg and for research purposes, no.  However, you will need a reference identification number (RIN) for Box 44 of your Customs’ Standard Administrative Document.

What do I have to do to export a chemical listed in Annex 1?

Complete an export notification by following our guidance on Exporting chemicals - What do I need to know?

Some chemicals require consent to be given before a shipment can occur, some only require that the importing country is 'notified' of the shipment.

My substance is listed in Part 1 of Annex 1 as being restricted because it is a pesticide, but the importers aren’t going to use it for this purpose, do I still need to notify?

Yes. For export notification, it is the substance that is in scope, not the use.

What if the details of an export notification change?

You should submit a new notification indicating that it revises a previous notification.

Changes that require a new notification include:

What if the importing country requests further information?

The DNA or other official bodies of the importing country may request further information.

Some requests are made directly to the DNA. For example, parties may implement the Rotterdam Convention more stringently and have additional information requirements. In order to respond, we may request more information from the exporter.

Some countries apply conditions and/or restrictions to imports in order to ensure compliance with national laws. Where these are a condition of the import consent, we will pass these on to the exporter. For example, countries may have a system for issuing import permits, and so whilst exports can proceed, you will still need to address these requests from the importing country to comply with their import procedures.

What if an importing country makes a decision to no longer allow import of a chemical? When do exporters to this country have to comply?

If the importing country is a Party to the Rotterdam Convention, they can inform the Rotterdam Convention secretariat who will publish the consent decision in the PIC Circular. The European Commission then have 6 months to implement measures to take account of this decision e.g. by amendment of the Regulation (EU) 649/2012.

Exporters can keep abreast of developments by consulting the PIC Circular

Not necessarily. Those listed in Part 3 of Annex I form the internationally agreed PIC list. These are substances banned or restricted in two or more countries or regions of the world (the EU Member States count only as one region, not as individual countries). Substances on this list do require consent. 

Many countries have already provided a decision on whether or not shipments can take place and these decisions are listed in the PIC Circular. If the response is ‘consent’, the export can proceed.  If  the response is ‘no consent’ or no response is listed in the PIC Circular then the exporter must submit an export notification and the DNA will act as an intermediary to see if that country is willing to accept the shipment.

The substances listed in Part 2 of Annex I are those that the European Commission consider ought to be on the PIC list but for which there is not yet international agreement. These substances are treated as if ‘consent’ needs to be given before shipment can occur. However if exporting to an OECD country the DNA may, in consultation with the Commission and on a case by case base, decide that no explicit consent is required if the chemical is licensed, registered or authorised in that OECD country.

Substances listed only on Part 1 of Annex I are banned/severely restricted in the EU only. ‘Consent’ is not required before shipment can occur, although it is necessary to submit an export notification.

How long does an explicit consent remain valid?

Where explicit consent is given, a new explicit consent shall be required by the end of the third calendar year, unless the conditions of that consent require otherwise. However, exports may continue for a further 12 months beyond this date whilst waiting for a response to a new request for explicit consent.

I wish to import a substance listed on Part 2 into the EU do I have to seek consent?

No. Under Regulation (EU) 649/2012 the EU importer does not have to seek consent, nor does the exporter in the third country. However, the importer must ensure that the intended use of the chemical is compatible with the EU restrictions and they should inform the DNA of the quantity of the substance imported each year.

If the chemical is banned or severely restricted under domestic legislation in the exporting country then, according to Article 8, the exporting country may send an export notification to the Commission, which will then be forwarded to the importing Member State

Updated: 2015-01-15