How companies from Bosnia and Herzegovina can submit a PCN notification in the European Union?

If your company is based in Bosnia and Herzegovina and exports chemical mixtures to the European Union, you have probably come across a PCN notification and UFI number.

If you are still unfamiliar with these terms, I recommend that you read this text first. And if you are familiar with the basics, let’s explore how companies based in Bosnia and Herzegovina can perform the mandatory PCN notification in the European Union.

A company headquartered in Bosnia and Herzegovina is considered a non-EU/EEA supplier. However, only companies based in the EU/EEA or Northern Ireland can submit a notification to the Poison Control Center (PCN) in accordance with the CLP Regulation.

A supplier from Bosnia and Herzegovina can submit a voluntary PCN notification, but only through a legal entity based in the EU/EEA. In this case, a voluntary UFI code is assigned to the Bosnian and Herzegovinian company. Buyers in the EU/EEA can use this code to perform the PCN notification as duty holders (importers of the mixture). Subsequently, they receive a new, unique UFI code.

The label of the mixture in circulation in the EU/EEA must indicate this new UFI code, not the voluntary UFI assigned to the company from Bosnia and Herzegovina. Including the voluntary UFI code on the label will not be legally valid, as a company outside the EU/EEA is not a duty holder in the EU/EEA. Voluntary PCN notification is a way for a company from Bosnia and Herzegovina to enable its EU/EEA customers to fulfill their obligations without disclosing the complete composition of the mixture.

If you have no issues with disclosing the exact composition
to your customers, then the step of voluntarily submitting a PCN notification is not necessary. In that case, you provide the necessary information to your importer, and they carry out the PCN notification. They inform you of their UFI code so that you can include it on the label/packaging of the products you export to the EU/EEA.

Bens Consulting, as a legal entity based in the EU, can perform a voluntary PCN notification on your behalf. Additionally, if needed, we can assist your importer in completing the PCN notification.

Sharing information in the supply chain for compliance with applicable regulations is crucial for a good collaboration between companies outside the EU/EEA and those within the EU/EEA. It is also a requirement for successful product sales in the EU/EEA territory.

If you would like to refresh your memory on the key facts about PCN notifications for companies outside the EU/EEA, please refer to this text.

If your company needs assistance with submitting PCN notifications, send an email to info@bens-consulting.eu. The Bens Consulting team will get back to you as soon as possible.

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