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Guidance

RINs and other codes

Under PIC, there is an obligation for exporters of chemicals or articles that contain substances listed in Annex I of this regulation (at concentrations that trigger labelling) to declare a ‘reference identification number’ (RIN) in box 44 of the Single Administrative Document.

These numbers are generated as part of the export notification procedure by the EDEXIM database, which is used to electronically record notifications.

RINs are not required for chemicals not listed in Annex I of Regulation.

Chemicals exported in quantities of 10 kg or less per annum for the purpose of research or analysis need a RIN even though the export does not require a notification.

Exports not requiring a RIN may still require a CHIEF code.

New CHIEF codes

Exporters should also use the Customs Handling of Import and Export Freight (CHIEF) document code, Y915 with SAD status codes (IP, XB or XX). More information is provided in HMRC Information Paper (08)67 available using the search facility at http://www.hmrc.gov.uk/index.htm.

The code Y915 means that a RIN is available confirming that the necessary permission has been given for the export of chemical substances and preparations in accordance with Regulation (EU) 649/2012.

Finding CAS and EINECS numbers

A CASRN or CAS Registry Number, commonly referred to as CAS Number, is a unique numerical identifier created and assigned to a chemical substance by Chemical Abstracts Service, a Division of the American Chemical Society.

An EINECS number is the numerical identifier assigned to chemical substances on the European Inventory of Existing Commercial Substances (EINECS). This is a list of the chemical substances available in the European Community market between 01 January 1971 and 18 September 1981.

You can use the chemical name in the European Chemical Substance Information System (ESIS) to find its CAS and EINECS numbers. On the ESIS home page, select substance name from the drop-down menu. Type the chemical name in the search box and click search.

The general information box provides the CAS and EINECS numbers under terms ‘CAS#’ and ‘EC#’ respectively.

Classification and labelling

Exported chemicals and those intended for export need to comply with the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009. These regulations came into force on 6 April 2009 and are known as CHIP 4.
They are gradually being replaced by the European Regulation on Classification, Labelling and Packaging of Substances and Mixtures, also known as the CLP regulation.

Safety data sheets

Safety Data Sheets in accordance with Regulation (EC) no. 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) need to accompany exported chemicals.

There is a requirement to provide safety data sheets in one or more principal languages of the destination country or location of the chemical’s use.

Languages to use for labels and safety data sheets

There are many widely available sources of information on commonly used languages. Standard internet searching of destination country languages will usually identify appropriate sources of information.

What a notification covers?

A notification covers all exports from an exporter of the same substance to the same country in the same calendar year. So one notification can cover independent shipments to different destination addresses within a country on different dates in each calendar year.

This also applies to preparations where differences in the notifiable substance concentration, result in no difference to the labelling of the preparation (in terms of the requirements for  symbols, hazard statements and risk and safety phrases under CHIP4 or pictograms, signal words, and hazard and precautionary phrases under CLP Regulation.

For example, if you export an Annex I Part I only listed substance from the UK to Switzerland and you intend to send 6 independent shipments to 6 different importers between 01 January 2010 and 31 December 2010, then you only need to notify the first shipment.  Because a notification lasts for one calendar year, your remaining 5 shipments are covered by it. It does not matter that you are sending the shipments to different importers in the same country, because this information is reported retrospectively in your annual tonnage return.

For preparations only containing a notifiable substance that triggers labelling, if you export this notifiable substance in two different preparations at  X %  and Y % respectively and both the presence of X% or Y% in the preparation triggers identical labelling then one notification would cover both of these exports. For preparations that also contain non-notifiable substances which trigger labelling, then if a change in the concentration of the notifiable substance leads to a change in the preparation's labelling then a new notification is required. Whereas if a change in the concentration of the non-notifiable substance leads to changes in the preparation’s labelling, then a new notification is not required.  In this case, the company would need to ensure that the product’s labelling and SDS were appropriately amended in accordance with the general export requirements.

For multiple preparations containing substances in Part 2 or 3 of Annex I at a concentration that triggers labelling, please contact UKDNA@hse.gsi.gov.uk to clarify how many notifications may be required. This is because some countries set consent restrictions such that each individual preparation may require a consent request and corresponding notification.'

Completing an export notification on-line using EDEXIM database

'To complete a notification form electronically, exporters need to obtain an online account by contacting the PIC DNA of the country in which they are registered. In Great Britain email UKDNA@hse.gsi.gov.uk with the subject line Edexim account request. In order for us to provide an online account we need to confirm that your exports contain substances listed on Annex I of Regulation (EU) 649/2012, and that your company is based in Great Britain. To demonstrate this, you should therefore provide:

Identity of one Annex I listed substance, name, CAS no. that you intend to export. In the case of a preparation, include the labelling requirement that would be triggered by the presence of this substance on its own.

Name, address, and web address of your company, including Company House registration number if available.

You should also send details of your preferred username. Username length must be 3 - 16 characters, you may use only letters, numbers and underscore, as other symbols ( e.g. * / & + \ , etc.) are not allowed. Completing notifications electronically reduces the time required to submit and allows you to track your notifications. For example, many of the fields are auto-completed or selected from drop-down lists.

In the absence of official guidance, the GB PIC DNA team has produced its own EDEXIM Data Entry Guidance[8].

Checking the PIC circular

The latest PIC Circular is available on EDEXIM and a User’s Guide to the PIC Circular was available on the Rotterdam Convention web site.

Carriage of dangerous goods

If the chemicals or articles are labelled as dangerous and are transported by road or rail during or prior to export, they need to comply with the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 200(CDG 2009) and the European Agreement concerning the International Carriage of Dangerous Goods by Road known as ADR, if applicable.

Updated: 2014-02-27