PIC
The Rotterdam Convention on the Prior Informed Consent Procedure for certain hazardous chemicals and pesticides in international trade
The Rotterdam Convention is an international treaty legally binding for all its member states. Pursuant to the provisions of this Convention, chemicals listed in Annex III may only be exported if a given state (party to the Convention) has consented to the import (Prior Informed Consent procedure – PIC procedure). The information on consents granted by specific parties to the Convention is published in PIC circulars. The Convention also requires that a party seeking to import chemicals whose manufacture or use is subject to a restriction or ban in its own territory must provide notice to the importing country of the proposed export. This requirement must be fulfilled before the date of first export and annually before the next export date (so-called “export notification” procedure). Countries that are parties to the Convention are also required to lead broad exchange of information on chemicals that are likely to be exported or imported. All the exported chemicals must be accompanied by the information on the labelling on the packaging and any other information on threats to health and the environment.
EU legislation
Regulation (EU) No 649/2012 of the European Parliament and of the Council of 4 July 2012 concerning the export and import of hazardous chemicals implements the Rotterdam Convention in the European Union. Regulation 649/2012 contains additional provisions which outreach the scope of the Convention to enhance the protection of health and the environment.
Text of this regulation in Polish is available HERE
Export of chemicals shall be notified in accordance with the provisions of Regulation 649/2012 via ePIC system following prior registration. The manual of registration and ePIC system use for industry is available in Polish and in English.
During the first quarter of each year, importers and exporters of chemicals listed in Annex I to Regulation 649/2012 are required to submit information regarding the quantities of these chemicals shipped (imported) to the EU territory or exported from the EU territory during the preceding year. This obligation concerns substances on their own, and contained in mixtures or articles. To submit the information on import/export of the chemicals, the importers/exporters need to register in the ePIC system and send a report generated by the system (Article 10 Report) to a designated national authority (Bureau for Chemical Substances is the DNA in Poland). Any technical issues with access to ePIC system can be notified using a form available on ECHA website. Additional information concerning the provisions of Regulation 649/2012 can be obtained from the Bureau for Chemical Substances: epic@chemikalia.gov.pl
Additional information:
Nicotine (CAS 54-11-5, EC 200-193-3) is subject to the provisions of Regulation (EU) 649/2012 of the European Parliament and of the Council of 4 July 2012 concerning the export and import of hazardous chemicals. It is listed in Annex I, Part 1 and 2 of this Regulation. Therefore nicotine is subject to export notification procedure and prior informed consent procedure (PIC procedure). This obligation is applicable regardless of the intended category of use.
Regulation (EU) 2017/852 of the European Parliament and of the Council of 17 May 2017 on mercury, and repealing Regulation (EC) No 1102/2008 bans any export of metallic mercury and certain mercury compounds and mixtures listed in Annex I to this Regulation from the dates laid down in this Annex. Regulation 2017/852 also imposes restrictions on the import of mercury, which vary depending on the source, the intended use and the place of origin of the mercury.