Time to notify the HSE of exports of PIC chemicals for 2024

On 9 August 2023, the British Health and Safety Executive (HSE) issued an e-bulletin inviting companies to notify the HSE of exports of chemicals in the Great Britain Prior Informed Consent (PIC) List anticipated to occur in 2024.

PIC – Prior Informed Consent

The Prior Informed Consent (PIC) regime in GB regulates the export and import of certain hazardous chemicals listed in the PIC List. The HSE is the PIC Designated National Authority (DNA) for Great Britain and administers the GB PIC regime including the export notification system and providing information on GB PIC.

The GB PIC Regulation requires that the initial export of a listed chemical to any country, in any calendar year, to be notified to the HSE at least 35 days before the planned date of export. This includes the transfer of a listed chemical from Great Britain to Northern Ireland.

How to apply for Export Notifications

• Complete a GB PIC export notification form

• Send completed forms to ukdna@hse.gov.uk with the following details in the subject line of the email: GB PIC - notification - company name - chemical/mixture - importing country name - 2024

• Attach only one export notification form and accompanying safety data sheet (SDS) to each email.

• In addition to an SDS in English, an SDS in the official language of the importing country should be provided if available, or in one of its principal languages. 

How to apply for Special Reference Identification Numbers

When exporting PIC chemicals for the purpose of research or analysis in quantities of 10 kg or less per exporter, per year and per importing country, Special Reference Identification Numbers (RINs) are required. A Special RIN is also required where an importing country has waived its right to receive an export notification and has notified a positive import response under the Rotterdam Convention for the chemical being exported. 

Special RIN requests for 2024 can now be submitted as follows:

• Complete a Special RIN request form

• Send the completed forms to ukdna@hse.gov.uk with the following details in the subject line of the email: GB PIC – Special RIN request - company name – chemical/mixture – importing country name – 2024

For exports of PIC chemicals to the EU, each Special RIN covers exports of up to 10kg of the substance for research and analysis purposes to each EU importing country.

Background – The Rotterdam Convention

The UK is a Party to the Rotterdam Convention on the Prior Informed Consent (PIC) procedure for certain hazardous chemicals and pesticides in international trade. The aims of the Rotterdam Convention are:

• To promote shared responsibility and cooperation in international trade of listed hazardous chemicals - through export notifications and the pic procedure.

• To protect human health and the environment by providing countries with information on how to store, transport, use and dispose of hazardous chemicals safely.

The PIC Regulation implements the Rotterdam Convention in GB but goes further by applying the requirements to chemicals that are banned or severely restricted in GB not just those listed in the Convention. You can find further information on the Rotterdam Convention website, including the latest PIC circular.