Effective 1 January 2027, distributors will be explicitly identified as duty holders under Article 45 of the Classification, Labelling and Packaging (CLP) Regulation. This clarification is intended to provide greater clarity regarding distributors’ responsibilities in supporting Poison Centre Notifications (PCN) requirements and to help address information gaps across the supply chain.
The clarification is particularly relevant to companies that:
- Sell mixtures in a member state and are not covered by an existing notification; or
- Rebrand products under their own name or label.
Companies potentially affected by these requirements should review the updated Steps for industry guidance to determine whether additional actions or notifications may be required beginning 1January 2027.
In addition, a corrigendum to the Guidance on Annex VIII to CLP for PCNs clarifies responsibilities for the labelling of imported mixtures with a Unique Formula Identifier (UFI). The updated text confirms that responsibility for placing the UFI on the product label rests with the European Union (EU) importer. Where products are labelled before being placed on the EU market, the use of the importer’s UFI is recommended.
The clarification does not introduce new obligations. Rather, it is intended to ensure that the respective responsibilities of companies involved in the supply chain are described consistently and accurately.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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