PCN enforcement: what the EU-wide inspection pilot found

On 11 February 2026 ECHA published the results of the Enforcement Forum’s pilot project on PCN enforcement (news item ECHA/NR/26/08). It’s the first EU-wide set of numbers on how many mixtures are notified, who the non-compliant companies are and what inspectors do about it. This article sets out those numbers, adds the national penalty frameworks the report doesn’t spell out, and separates the pilot from REF-14, the larger enforcement project running through 2026. A targeted enforcement project, not a measure of the whole market.

The pilot in numbers

Between January and June 2025, inspectors in 18 EU/EEA countries checked 1,597 mixtures against the Article 45 and Annex VIII duties. 19% of the mixtures that required a poison centre notification had none. The rate is calculated on the 1,432 mixtures where a PCN was required, so out-of-scope products don’t dilute it. Roughly one hazardous mixture in five, with nothing on file at the poison centre that would answer a call about it.

The second measure was the label. Where a UFI was required on it, 15% of checked mixtures had none. It’s the quickest finding an inspector can make: no database needed, just the label. How the two halves relate is in UFI vs PCN.

Two more findings frame the rest. 71% of inspected mixtures came from SMEs. Size made little difference: the compliance rate was 59% for SMEs and 58% for large companies. A bigger regulatory department didn’t buy a better result.

Chris Van den hole, chair of the pilot’s working group, put the stakes plainly: “Missing notifications of the necessary information to the poison centres undermine the effectiveness of emergency response.” The quote continues: inspectors “take these findings very seriously and initiated numerous enforcement actions to bring companies to compliance.”

The 656 enforcement actions

Inspectors took measures in 656 reported non-compliant cases, scaled to severity:

Read the table both ways. 83% of measures were advice, written or verbal, so a first finding is more likely to produce a deadline than a penalty. In the same six months, inspectors also issued 72 orders, 30 fines and put 29 files in front of prosecutors. Advice comes with rectification expected.

What penalties look like nationally

CLP leaves penalties to member states, so the downside of the same missing notification varies by market. Three concrete frameworks:

• Germany (country guide): breaches of chemicals-law duties are administrative offences under § 26 of the Chemikaliengesetz, with fines up to €50,000 in the statute’s top administrative tier (lesser infringements carry a lower ceiling).
• France (country guide): the Code de l’environnement provides administrative fines up to €15,000 plus a daily penalty of €1,500 until compliance (Art. L521-18), and a separate criminal track, up to two years’ imprisonment and €75,000, for knowingly providing false information or withholding required data (Art. L521-21).
• Lithuania (country guide): the Code of Administrative Offences (ANK) Art. 308 fines the responsible individuals personally: €150-1,450 under Art. 308(5), rising to €340-4,300 under Art. 308(16), a reminder that in some states the name on the fine is a manager’s, not the company’s.

Set these against the cost of doing the work, which is in what a PCN costs.

REF-14: the separate, ongoing 2026 project

The pilot is finished; enforcement is not. REF-14 is the Enforcement Forum’s next coordinated project: a distinct and larger exercise, prepared with inspector training through the end of 2025, with inspections running through 2026 and a report expected in 2027. Its scope is broader than the pilot’s: classification, labelling and packaging of mixtures (including child-resistant fastenings), poison centre notifications, and safety data sheets of hazardous mixtures in consumer products, plus checks under REACH restrictions and the POPs Regulation.

Before an inspection

The pilot report doubles as a list of what gets found. Working through it in advance:

1. List every hazardous mixture on the market and confirm which require notification. The scope walk-through is in do I need to submit a PCN.
2. Reconcile labels against notifications: every required UFI on the label, every UFI backed by a notification that passed ECHA’s validation and covers the markets you sell in.
3. Close the gaps. All deadlines have passed and the duty is continuous, so a late notification is the only option left (see PCN deadlines for how to sequence a backlog).
4. Keep proof. Submission numbers and dates, retrievable when asked.

Most of what the pilot found drew advice, with rectification expected, rather than a penalty. UFI Number is built to prepare poison centre notifications from data you already hold and to send them through ECHA's official system-to-system route. It's in private beta.