The hidden risk of outdated PCNs: why ceasing market placement matters

27 Feb 2026

It is paramount that products notified by businesses continue to remain compliant after an initial Poison Centre Notification (PCN) has been submitted.

Keeping notifications up to date ensures that medical professionals have accurate information to respond effectively in an emergency involving your product, while also safeguarding your business against regulatory non-compliance and potential enforcement actions. This dual focus – protecting health and maintaining compliance – helps uphold both public safety and your company’s reputation.

Businesses must maintain their PCNs by updating the information as appropriate, but there may come a time when their product is no longer on a specific market. Once a product is no longer shipped to countries it has been notified to, it’s PCN must be updated to “Cease Market” for those relevant countries.

In 2025, ECHA’s regulation compliance enforcement project, REF-12, reported on compliance across REACH, CLP, and Prior Informed Consent (PIC) regulations which includes Poison Centre Notification compliance. Therefore, it should be of principal concern to ensure that PCN portfolios are up to date.

Active vs in-active PCNs

Once a product is no longer placed on the market due to no longer being manufactured, or no longer being imported, its PCN will remain active until its updated to “Cease Market” for the country it has been notified in.

What happens to the information of a ‘cease marketed’ PCN

As the shelf life of a product can go years, even decades beyond the production of its last marketed batch, the relevant information is still held by ECHA and relevant Poison Centres in case of a future poisoning incident or emergency involving the product.

Why is this important

There are obligations to keep PCNs up to date, which include but are not limited to:

Change in composition
Change in packaging
Updated hazard classification
Updated toxicological information is available
New tradenames and translations
Updated pH information

Many of these no longer apply to products that have ceased market, including the regulator ATP to CLP updates, which could see substances within the products reclassified. This has a knock-on effect of requiring the products’ PCNs to be updated, stating the new substance classifications, but only applies to active products. Once a product’s PCN is ‘ceased market’, there is no obligation to update it for ATP updates.

If a product contains a mixture supplied by another company and they change their formula, it could also affect the original product and require the PCN to be updated – again, this is only relevant if the original product is active and if the original product has ceased market, there would be no obligation to update the PCN.

Ceased market products protect a business from scrutiny if an audit or random spot check to PCNs were to be conducted by ECHA as these PCNs are not considered ‘active’.

However, this does not mean there are no obligations. In the case that significant information for the product becomes available after its last placement on the market and since the PCN dossier was ‘ceased market’, the PCN can still be updated (voluntary but recommended) to ensure the most accurate information is available, as Member States may still request additional information in the case of a poisoning emergency.

How can Ricardo help?

When a product is no longer placed onto one or multiple markets, or has ceased being produced altogether, Ricardo can update the product PCN and provide businesses with the assurance that their product portfolio is compliant with all applicable regulations.

Don’t leave your PCN portfolio exposed to compliance risks. When a product stops being placed on one or more markets, or production ceases entirely, Ricardo acts fast to update your PCNs to “Cease Market” status across all relevant countries.

By partnering with Ricardo, you:

Eliminate regulatory risk from outdated notifications.
Protect your brand from enforcement actions and audits.
Gain peace of mind knowing your portfolio is fully compliant.

Stay ahead of compliance changes by monitoring your substance portfolio with Chemical Compliance Monitor, helping you identify updates that may impact ceased PCNs before they become a risk.