EU Updates Hazardous Chemicals Import and Export List, Effective January 2026

The European Commission has recently announced proposed revisions to the EU Prior Informed Consent (PIC) Regulation on the import and export of hazardous chemicals. These updates are based on recent amendments to EU regulations such as REACH, POPs, CLP, and BPR, and are aimed at strengthening control over chemicals involved in international trade. The public consultation period runs from July 14 to August 11 (midnight, Brussels time).

This draft represents the latest revision of Regulation (EU) No 649/2012 on the export and import of hazardous chemicals, aligning with recent developments under the Stockholm Convention (POPs), the Rotterdam Convention (PIC), and various EU chemical regulations (e.g., REACH, the Plant Protection Products Regulation, and the Biocidal Products Regulation).

1. Significant Expansion of Covered Substances

The draft proposes additions and updates to Annex I (subject to notification) and Annex V (prohibited for export). Substances include, but are not limited to:

* UV absorbers/stabilizers: UV-328, UV-327, UV-320, UV-350

* Flame retardants/plasticizers: DEHP, DBP, MOCA, DOTE/MOTE

* Heavy metal compounds: Arsenic trioxide, potassium/sodium/ammonium chromate, chromic acid

* Pesticides/biocides: Carbendazim, Metribuzin, Dodemorph, Dechlorane Plus

* Others: PHMB (polyhexamethylene biguanide hydrochloride), trichloroethylene

2. Export Exemptions for UV-328, Dechlorane Plus, etc.

Exports of certain substances such as UV-328 and Dechlorane Plus may be allowed only if:

* They fall under specific exemption conditions listed in Annex I of the POPs Regulation; or

* Their concentration is below the threshold limit (e.g., UV-328 below 1 mg/kg)

3. Legal Frameworks Referenced

This revision is based on the following legislative instruments:

* REACH Regulation (EC) No 1907/2006

* CLP Regulation (EC) No 1272/2008

* Biocidal Products Regulation (EU) No 528/2012

* Plant Protection Products Regulation (EC) No 1107/2009

* The Stockholm and Rotterdam Conventions

1. Chemical, Plastics, Coatings, and Rubber Industries

Products containing UV stabilizers such as UV-328/320/327/350 may face new requirements, including export notification, usage restrictions, or complete bans (based on REACH and POPs rules). Applications in automotive interiors, consumer electronics casings, coatings, and films may require reformulation or substitution.

2. Electronics and Electrical (E\&E) Supply Chains

Use of SVHCs like MOCA, DEHP, and DOTE/MOTE may trigger REACH authorization, export notification, and stricter quality control from downstream customers. Affected products include plastic housings, cables, connectors, and adhesives.

3. Pesticide and Insecticide Exporters

Certain pesticides (e.g., Carbendazim, Metribuzin, Pyridalyl) already banned or withdrawn within the EU will fall under the PIC mandatory notification system. Exports containing such substances will require prior informed consent (PIC) from the destination country-adding complexity and increasing compliance costs.

4. Automotive, Packaging, and Building Materials Sectors

Chromium compounds and other carcinogenic, mutagenic, or reprotoxic (CMR) substances-such as chromates and coal tar pitches-will face stricter controls, affecting applications such as paints, coatings, electroplated parts, and preservatives.

1. Product Screening: Build a robust chemical substance database to identify whether products contain substances such as UV-328, Dechlorane Plus, MOCA, or chromates.

2. Substitution and Reformulation: Initiate R\&D efforts to replace SVHCs with safer alternatives and avoid the need for future authorization.

3. Client Communication and Role Definition: Clarify chemical compliance responsibilities with clients or brand owners; establish systems for chemical information sharing to avoid product recalls, border rejections, or reputational risks.

4. Export Notification Preparation: For products subject to PIC notification, work with EU importers in advance or consider using third-party representatives to handle notifications.

5. Monitor Regulatory Developments: As the draft regulation is expected to take effect on January 1, 2026, companies should complete compliance adjustments at least six months prior.

This regulatory update demonstrates the EU’s continued tightening of controls on chemical exports-particularly persistent organic pollutants (POPs) and high-risk industrial chemicals (CMRs). Exporters worldwide should promptly assess risks associated with their products and enhance their compliance management systems to mitigate notification or prohibition risks and ensure long-term business continuity.