European Commission Reviews Implementation of EU PIC Regulation for 2020–2022

On 30 September 2025, the European Commission published its Synthesis Report on the Operation of Regulation (EU) No 649/2012 concerning the export and import of hazardous chemicals for the period 2020–2022. The report reviews the implementation of the Prior Informed Consent (PIC) Regulation across the EU and outlines the latest changes to Annex I.

New substances and updates to Annex I

Several chemicals were added or reclassified under Annex I between 2020 and 2022, expanding the list of substances subject to export notification or explicit consent requirements. Newly listed entries include perfluorooctanoic acid (PFOA) and related compounds, decabromodiphenyl ether (decaBDE), and chlorinated paraffins (C10–C13).

Some existing substances were also moved from Part 1 (notification only) to Part 2 (notification and explicit consent) of Annex I, which further tightens controls on exports. These changes bring the EU Regulation into line with recent decisions under the Rotterdam Convention and strengthen oversight of the trade with hazardous chemical.

In addition, Annex V was expanded to include new export bans for substances such as dicofol, pentachlorophenol, PFOS, PFOA, and decaBDE, as well as certain mercury compounds and mercury-added products.

Implementation findings

The Commission concludes that the PIC system functions effectively, though national authorities continue to face resource constraints and administrative pressure from frequent updates to the annexes. ECHA processed around 10,000 export notifications in 2022 and continued to improve its ePIC system. Enforcement activities by Member States remained stable, focusing on preventing unauthorised exports and ensuring proper documentation.

Outlook

The report recommends the further simplification of annex amendment timelines, the enhancement of user guidance within the ePIC system, and the improvement of support for Designated National Authorities. Overall, the Regulation is considered to be meeting its objectives while adapting to evolving international obligations.

The full text of the report can be found here.