Exporting GB PIC-listed chemicals

GB PIC places obligations on companies who wish to export or import certain (PIC-listed) chemicals into or out of GB. The obligations mostly apply to exports and this includes companies having to notify their intention to export substances.

You can check which chemicals are subject to GB PIC on the GB PIC List. If substances are not listed, then there are no PIC notification obligations.

Companies exporting PIC-listed chemicals from GB are required to notify to HSE exports of:

• any chemical listed in Part 1 of the GB PIC List.
• mixtures that contain any of these Part 1 chemicals in a concentration that triggers an obligation to label under GB CLP Chemical classification overview.
• articles that contain in unreacted form either:
  • (i) a chemical listed in Part 2 or Part 3 of the GB PIC List
  • (ii) mixtures that contain these chemicals in a concentration that triggers labelling obligations under GB CLP.

Companies should notify their exports to the GB PIC Designated National Authority (DNA):

• For each substance, mixture or article to each importing country. This applies irrespective of the intended use in the importing country.
• At least 35 days before the first export in any calendar year to any importing country. They must then notify at least 35 days before every first export to each importing country in each subsequent calendar years
• By completing a GB PIC export notification. The forms are similar to those used under EU PIC.

Note, that for exports to the EU, a single notification will cover exports of that product going to any EU member state or supply to Northern Ireland.

Special procedures apply to PIC in cases of:

• Emergency - here an emergency export notification may be submitted in cases of public health or environmental emergency where delay could worsen the situation in the destination country. The usual requirement to submit the notification 35 days prior to export does not apply, and emergency notifications are not subject to the explicit consent procedure. Please provide further details of the emergency situation with your submission of the export notification form.
• Special RIN requests - where those chemicals are exported for research or development in quantities of up to 10 kg per year to each importing country.

In addition to notifying exports, companies exporting PIC-listed chemicals from GB are obliged to:

• Report yearly quantities of each PIC-listed chemical exported during the previous calendar year.
• Comply with general export requirements - chemicals that are intended for export must be packaged and labelled in the same way as if they were to be marketed in the GB unless the importing country has its own specific requirements, considering also relevant international standards.

Companies may also wish to check with the relevant authorities in the importing country as to whether they have any existing national laws or restrictions for the import of their chemicals into a country.

Explicit consent waivers

For some chemicals the explicit consent of the importing country is required before export can take place, and the GB PIC DNA seeks this consent on behalf of the exporter. But, in certain circumstances a valid positive explicit consent response from importing country can be waived. Find out more in our guide Exporting PIC chemicals from GB: waivers.