Post-submission responsibilities: maintaining compliance after the 2025 Poison Centre Notification deadline

With the Poison Centre Notification (PCN) transition period officially concluded on 1 January 2025, businesses placing hazardous mixtures on the EU market are now required to have submitted notifications to ECHA, complete with the relevant Unique Formula Identifiers (UFIs). 

For many, this marked the culmination of a significant compliance effort. However, it's important to recognise that submission is not the end of the process. Once a PCN is submitted, it doesn’t simply sit in a drawer collecting dust; it’s a living document that needs to reflect the current state of your product. That means any change – whether from inside your organisation or driven by the evolving regulatory landscape – can trigger the need for updates.

Why maintenance matters

PCNs exist to protect public health. When a poisoning incident occurs, medical professionals rely on the data you've submitted to determine the best course of treatment. If your product’s formulation or hazard classification changes and your PCN isn’t updated, the consequences could be serious – for both patients and your compliance status.

The evolving regulatory landscape

Regulations are constantly evolving, and your compliance must evolve with them. Several developments are already on the horizon:

• Endocrine Disruptors for Human Health
• Endocrine Disruptors for Environment

These will soon be introduced, and any affected substances or mixtures must be reclassified accordingly, which may lead to your product being reclassified. Due to a substance within, or the overall mixture, your PCN will need to be updated to include this new classification to remain compliant and accurate.

Read more: New CLP Hazard Classes: are your chemicals compliant?

In addition, the 23rd Adaptation to Technical Progress (ATP 23) – expected in summer 2025 – may result in reclassification of certain substances with more severe hazard profiles. If your product contains any of these substances, your PCN will need to be updated accordingly.

These are examples of external drivers of change, but internal changes can be just as important.

Internal product changes and supplier variability

Changes within your own business, through product development or the supply chain, can also trigger PCN updates. While these changes might seem routine or low risk, they can have significant implications for compliance.

Consider the following scenarios:

• What happens if a supplier discontinues a component?
• Can you source the same component from an alternative supplier?
• Can a seemingly identical alternative be substituted?
• Will the alternative require you to re-formulate the product?
• Will that reformulation alter the mixture’s hazardous properties?
• Will this affect the classification or composition of the product?
• Will that trigger the need for a new UFI?
• Will the packaging or labelling need to be updated?

If changes aren’t identified and acted upon quickly, your PCN could fall out of compliance, leaving you exposed to regulatory risk and potential supply chain disruption.

In the event of a poisoning incident, outdated information could delay treatment and jeopardise patient safety. Supply chain variability is also a growing concern. With increased global sourcing, securing consistent raw material quality isn’t always guaranteed. If using multiple suppliers for a key component, you may be able to take advantage of Interchangeable Components Groups (ICGs) under the PCN framework, but strict criteria apply, and not all components qualify.

In short, maintaining compliance isn’t just about checking boxes, it requires continuous awareness of what’s changing inside and outside your business, and how those changes affect your regulatory obligations.

How can Ricardo help?

For external changes, our Chemical Compliance Monitor (CCM) helps you stay ahead of the curve. By scanning a wide range of regulatory databases, CCM identifies upcoming changes that may impact your products and pro-actively alerts you before they become urgent.

• If a substance is being phased out, you'll have time to find a substitute, Ricardo will help assess the impact on your product portfolio.
• If a substance becomes more hazardous causing new packaging to be used, you’ll have a head start implementing these changes with Ricardo pinpointing what is needed.

Learn more: Chemical Compliance Monitor (CCM)

For internal changes, Ricardo offers UFI Impact Assessments to evaluate any potential modifications in formulation or supply chain.

• Changing suppliers? Send us the SDS of the new component—we’ll compare it against your current data to determine whether a PCN update or new UFI is required.
• Sourcing a component from multiple suppliers? We can advise on using Interchangeable Components Groups (ICGs) as permitted under the regulations.

Stay compliant – without the stress

Before you make any product changes, talk to Ricardo. We'll help assess the regulatory impact, manage your UFIs, and ensure your PCNs remain accurate and up to date. And while we handle the complexity, you can focus on your business – knowing your compliance is in good hands.

Speak to an expert

Learn more: Regulatory and Compliance Solutions