EU expands the PIC Regulation: more than 30 additional chemicals subject to export notification from 1 October 2026
The European Commission has adopted Commission Delegated Regulation (EU) 2026/1278, amending Annex I and Annex V of Regulation (EU) No 649/2012, better known as the PIC Regulation. With this amendment, more than 30 substances are added to the list of chemicals whose export from the European Union triggers a notification duty and, depending on the annex part, the prior informed consent procedure. The amended rules apply from 1 October 2026.

For exporters of plant protection products, biocides and industrial chemicals this is a familiar but consequential exercise. Every additional entry in Annex I means additional administrative steps, longer lead times and, in the worst case, a shipment that cannot leave the EU because the notification was filed too late.

What the PIC Regulation does

The PIC Regulation implements the Rotterdam Convention within the European Union. It governs the export and import of hazardous chemicals and gives importing countries the opportunity to decide, on an informed basis, whether they wish to receive a given substance. Annex I is structured in three parts, and the part in which a substance is listed determines the obligations that follow.

Part 1 covers chemicals subject to the export notification procedure.

Part 2 covers chemicals that additionally qualify for PIC notification, meaning explicit consent from the importing country may be required.

Part 3 covers chemicals listed under Annex III of the Rotterdam Convention, which are fully subject to the PIC procedure.

Annex V lists chemicals whose export is prohibited altogether.

What is changing

The amendment reflects regulatory developments that have taken place at EU and international level since the last review. In substance, the changes fall into four groups.

1. Non approval, withdrawal or restriction decisions under the Plant Protection Products Regulation (EC) No 1107/2009, which move a number of active substances into the export notification regime.
2. Decisions under the Biocidal Products Regulation (EU) No 528/2012 concerning active substances that are no longer supported or approved.
3. REACH authorisation and restriction measures, including substances of very high concern such as certain benzotriazole UV stabilisers, phthalates and chromium compounds.
4. Listings adopted under the Stockholm Convention on Persistent Organic Pollutants, which are mirrored in Annex V as export prohibitions. UV-328, Dechlorane Plus and methoxychlor are the relevant entries here.

Alongside the additions, the amendment also corrects and clarifies a number of existing entries, including a reclassification of carbosulfan and an updated treatment of fenthion formulations, and it aligns customs codes where these had become inaccurate.

Why this matters for exporters

The PIC procedure is a timing problem before it is a paperwork problem. Under Article 8 of the Regulation, the exporter must submit an export notification to the designated national authority of its Member State at least 35 calendar days before the intended date of export. The authority forwards the notification to ECHA, which passes it to the importing country. Where a substance is listed in Part 2 or Part 3 of Annex I, explicit consent from the importing country may be required before the export can proceed, and obtaining that consent regularly takes weeks or months rather than days.

ECHA has already added the new entries to the ePIC database, so companies can prepare and submit notifications for exports taking place from October onwards without waiting for the date of application.

Recommended next steps

1. Compare your export portfolio, including mixtures and articles where relevant, against the amended Annex I. Concentration thresholds matter, because a substance present in a mixture above the relevant limit brings the mixture into scope.
2. Check whether any of your substances appear in the amended Annex V, since an export ban cannot be solved by a notification.
3. Identify the destination countries concerned and establish whether explicit consent is required or whether an existing consent or waiver can be relied upon.
4. Register or update your company details in ePIC and make sure the responsible persons have valid access.
5. Prepare and submit notifications early rather than at the 35 day minimum, so that queries from the authority do not put the shipment at risk.
6. Update your internal substance master data, safety data sheets and order acceptance checks so that a PIC relevant order is flagged before it is confirmed to the customer.

Our assessment

The annual Annex I review is a predictable process, and that is precisely why it is often underestimated. Companies that treat PIC as an annual project tend to be caught out. Companies that build the Annex I check into their normal order and product release workflow tend not to be. The 1 October 2026 date is far enough away to be manageable and close enough to justify starting now.

If you would like support in screening your portfolio against the amended annexes or in setting up your notification process in ePIC, we are happy to help.