PCN deadlines: every date has passed - what applies now

Every PCN deadline has already passed. The last one expired on 1 January 2025. There is no date ahead by which existing duty holders must file, because the obligation stopped being a calendar event and became a standing condition of selling hazardous mixtures in the EU and EEA.

The dates still matter. They explain which products should already be notified today, and they matter if you’re finding, as companies did in ECHA’s 2025 enforcement checks, that some of yours aren’t.

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. The transition row is the one behind the “PCN deadline 2025” searches: a company that had notified under a pre-Annex VIII national scheme could rely on those submissions until 1 January 2025, unless the product changed earlier and pulled the harmonised duty forward. Since that date, only notifications in the harmonised format, with a UFI, satisfy Article 45. Which mixtures are 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” isn’t a relaxation. The notification is a gate you pass before each product goes on sale, and in practice that means:

• 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 the label artwork.
• 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. Six states (Belgium, France, Germany, Italy, Luxembourg and Spain) also 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.

The deadlines didn’t disappear. They multiplied: each product, market entry and reformulation now carries its own, 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 move is unglamorous: notify now. There’s no amnesty and no late-filing procedure. The same portal accepts the same dossier whether you’re early or three years behind.

In the Forum’s 2025 pilot (ECHA/NR/26/08), inspectors found that 19% of the mixtures requiring notification had none. Most measures were written advice (68%); fines (5%) and criminal complaints (4%) were the sharp end. A targeted enforcement project, not a measure of the whole market. The full figures 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 come from the 2024 CLP revision, Regulation (EU) 2024/2865, not from Annex VIII’s original phase-in, which is finished:

A third date exists but isn’t 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 leaves alone, is in Regulation (EU) 2024/2865.

If you searched for a deadline because of a backlog you already know about, what limits you is the hours per dossier. You can do all of it in ECHA’s portal, and it’s free. UFI Number is built for the repeat: the UFI, the notification in the current format, sending it and keeping the submission number. It’s in private beta.