Do you need to update your Poison Centre Notifications? Key triggers explained

In the post-transition landscape PCNs are critical for ensuring that accurate information is provided when dealing with chemical incidents. However, these notifications only serve their purpose if the data they contain is kept up to date.

In this article, we’ll explain when you need to update a previously submitted notification to reflect changes in your mixture.

Why updates matter

An outdated PCN can lead to incorrect advice during an emergency, potentially putting lives at risk. Regulatory frameworks such as Annex VIII of CLP require updates whenever significant changes occur in your product.

What changes require a notification update?

You must update your PCN if any of the following occur:

• Change in composition
• Change in composition/UFI of a mixture-in-mixture (MiM)
• Change in market placement
• Change in hazard classification of the overall product
• Change in trade name
• New toxicological information becomes available

What composition changes trigger an update?

You’ll need to update your PCN if there are significant changes to your product’s formulation. Common triggers include:

• Changes to the formulation – Adding, removing, or substituting ingredients.
• Adjustments in concentration – If ingredient levels move outside the ranges you originally declared.
• New hazard information – If the classification of your product or any component changes.

When do you need a new UFI?

A new UFI is required when:

• You change the mixture’s composition significantly
• You create a new product variant
• You alter the mixture-in-mixture UFI

External regulatory changes: why they matter

It’s not just changes to your own product that can trigger a PCN update - regulatory changes can too.

Every year, the European Commission updates the harmonised classification of hazardous substances through Adaptations to Technical Progress (ATPs) under the CLP Regulation. These changes are legally binding and can impact your product’s classification, labelling, SDS, and PCNs.

The most recent ATP, the 23rd ATP, published on 20 June 2025, introduced new harmonised classifications for 22 substances and updates for 10 more. These changes must be adopted by 1 February 2027.

Key highlights:

• Nitrous oxide is reclassified as a Category 1B reproductive toxicant in the EU—a major change with implications for the food and cosmetics industries.
• Several substances used in cosmetics, such as fragrances and preservatives, also received new classifications.

Find out more about the 23rd ATP >

Other reasons you may need to update

• Expanding the markets where your product is sold
• Updating emergency phone numbers in limited submissions
• Changes to packaging information such as trade name or labelling
• Interchangeable Component Group (ICG) adjustments

Keeping your Poison Centre Notifications up to date is essential for compliance and safety. Whether changes come from your own product formulation, new hazard information, or external regulatory updates like ATPs, timely updates ensure emergency responders have accurate data when it matters most.

If you’re unsure whether a change triggers an update – or need help navigating complex regulatory requirements – our experts can guide you through the process and keep your notifications compliant across all markets.

Contact our experts today >

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