PCN deadlines: every date has passed — what applies now

If you are searching for the poison centre notification deadline, here is the answer nobody puts in the first sentence: every PCN deadline has already passed. The last one expired on 1 January 2025. There is no date in the future by which existing duty holders must file — because the obligation stopped being a calendar event and became a permanent condition of selling hazardous mixtures in the EU and EEA.

That does not make the dates irrelevant. They explain which products should already be notified today, and they matter if you are discovering — as a substantial share of companies did during ECHA’s 2025 enforcement checks — that some of yours are not.

The dates that have passed

Two footnotes to that table. The consumer-use date was originally 1 January 2020 and was deferred a year by Delegated Regulation (EU) 2020/11, which is why older articles cite 2020. And the transition row is the one that generates the “PCN deadline 2025” searches: companies that had notified under a pre-Annex VIII national scheme could rely on those submissions until 1 January 2025 — unless the product changed earlier, which pulled the harmonised duty forward. Since that date, only notifications in the harmonised format, with a UFI, satisfy Article 45. Which mixtures fall in scope at all is covered in do I need to submit a PCN; the use-type distinctions live in consumer, professional and industrial use.

What a continuous obligation means in practice

“No deadline” is not a relaxation. It means the notification is a gate, not a filing season. Operationally:

• Every new product classified for health or physical hazards needs its notification submitted before the first unit is placed on the market. It belongs on the launch checklist next to label artwork, not in a year-end compliance batch.
• Every new market needs coverage before first supply there. A notification names the member states it covers; entering Austria with a product notified for Germany means updating the notification first. Several states — Belgium, France, Germany, Italy, Luxembourg and Spain — additionally expect confirmation of receipt before the product ships.
• Every relevant change — composition beyond the permitted ranges, classification, product category, packaging — triggers an update, on the timelines described in how to update a PCN.

In other words, the deadlines did not disappear; they multiplied. Each product, market entry and reformulation now carries its own private deadline: the day you place it on the market.

If you discover you are late

Suppose the audit turns up products on sale since 2022 with no notification, or with only a defunct national one. The correct move is unglamorous: notify now. There is no formal amnesty and no late-filing procedure — the same portal accepts the same dossier whether you are early or three years behind — but the enforcement record shows why acting first matters. In the Forum’s 2025 pilot, inspectors found 19% of mixtures requiring notification had none; the dominant response was written rectification advice (68% of measures), with fines (5%) and criminal complaints (4%) reserved for the sharper end. A company that has already fixed its gap when the inspector arrives is in a categorically better position than one that gets found — the full statistics are in PCN enforcement.

Work the backlog in a defensible order:

1. Inventory every mixture on the EU/EEA market and its classification.
2. Sort the in-scope ones by exposure: consumer products first (they dominated inspections — 83% of mixtures checked in the pilot were consumer-facing), then professional, then industrial.
3. Submit the missing notifications and fix labels missing a UFI as artwork cycles allow — the process is in how to submit a PCN.
4. Record dates and submission numbers, so the paper trail shows self-correction rather than discovery.

The only dates still on the calendar

The dates ahead do not come from Annex VIII’s original phase-in — that is finished — but from the 2024 CLP revision, Regulation (EU) 2024/2865:

(A third date exists but is not about poison centres: Regulation (EU) 2025/2439 deferred the revision’s label-formatting, advertising and distance-sales rules to 1 January 2028.) For importers and downstream users already carrying the duty, neither 2026 date changes anything — your obligation has been live for years. The 1 January 2027 date matters chiefly to distributors, who join the duty-holder list in defined cases. What the revision changes, and what it deliberately leaves alone, is unpacked in Regulation (EU) 2024/2865.

If the reason you searched for a deadline is a backlog you already know about, the constraint is rarely the calendar — it is the hours per dossier. Compressing those hours is the entire point of Ufi Number: UFI, dossier in the current required format, submission and acknowledgement, at €20 per mixture.