Fuels and Poison Centre Notifications: understanding requirements

Certain fuels are within scope of Poison Centre Notifications (PCNs) but are treated differently from other mixtures due to their complex compositions. Given the intricacies of the refining process and the natural variation in raw materials, it is challenging to define an exact chemical composition for fuels. As a result, the Classification, Labelling, and Packaging (CLP) Regulation gives some flexibility when notifying fuels, compared to other mixtures.

Why are fuels reported differently?

Unlike more straightforward chemical formulations, fuels are derived from crude oil, which undergoes refining processes that can lead to variations in composition. This makes it difficult to provide a definitive list of ingredients in the way that is typically required for a standard PCN submission.

Recognising this complexity, the CLP Regulation allows the composition from the fuel’s Safety Data Sheet (SDS) to be used instead of the full composition. Additionally, the identity and concentration of any other known components shall also be included in the submission.

Key considerations for fuels in PCNs

• Scope of PCN requirements: fuels fall under the remit of PCN obligations meaning companies dealing with these substances must submit notifications in compliance with CLP Regulation Annex VIII requirements.
• UFI and reporting challenges: each submitted fuel must have an associated Unique Formula Identifier (UFI) so that in a poisoning emergency, health care professionals and emergency responders can ensure an accurate match between the fuel and its composition.
• List of fuels: The following table outlines the fuels that benefit from the regulatory flexibility provided by the CLP Regulation. Products can only notify as a “fuel” if included on this list, otherwise products would be treated as a standard mixture under CLP, meaning we need full composition.

Please note that this list is exhaustive according to the CLP guidelines, available here:

Sustainability support

Beyond Poison Centre compliance, fuel producers are increasingly affected by EU-wide sustainability regulations aimed at reducing greenhouse gas emissions and promoting the use of renewable energy in transport. Key pieces of legislation – including RED II, RefuelEU Aviation, and FuelEU Maritime – play a central role in shaping the future of fuel production and use. These frameworks introduce new targets and sustainability criteria that fuel manufacturers must consider as part of their operational and strategic planning:

1.    REDII (Renewable Energy Directive II):
   • Establishes a fossil fuel baseline of 94gCO2eq per MJ.
   • Requires a 70% reduction in emissions for Renewable Fuels of Non-Biological Origin (RFNBOs).
2. Refuel EU Aviation (Aviation Fuels):
   
   • Mandates a gradual increase in Sustainable Aviation Fuel (SAF) blending into conventional aviation fuel (2% by 2025, 6% by 2030, 70% by 2050).
   • SAF must achieve at least a 65% reduction in emissions to qualify.
3. FuelEU Marine (Marine Fuels):
   
   • Sets Greenhouse Gas (GHG) intensity limits for marine fuels' well-to-wake emissions (34.6gCO2eq per MJ by 2045 and 18.2gCO2eq per MJ by 2050).
   • Introduces a specific calculation methodology to assess emissions.

Expert support 

Navigating regulatory obligations for businesses handling fuels can be complex, but expert support is available to help you manage both PCN requirements and sustainability regulations, whether you need clarification on reporting procedures or guidance on ensuring compliance.

If you're unsure about how to navigate your regulatory obligations related to fuels, contact our team today. Our expertise ensures that you meet these requirements confidently, minimizing risks and avoiding unnecessary complications.

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