From 1 January 2027, a new obligation will take effect in Belgium — and across the entire European Union — for distributors of hazardous mixtures. They will then be explicitly designated as the responsible party for submitting poison centre notifications (PCN) to the European Chemicals Agency (ECHA). This is reported by the Belgian prevention association Prebes, based on a recent clarification from ECHA.
New responsibility for distributors
Until now, the duty to submit PCN notifications — which include the unique formula identifier (UFI) — rested mainly with manufacturers and importers of hazardous mixtures. These notifications allow poison centres and emergency services to quickly look up a product’s correct composition and toxicological data in the event of poisoning or a chemical incident. Under the revision of the CLP Regulation (Regulation (EU) 2024/2865), part of that responsibility now also falls on distributors, pursuant to Article 45. The aim is to close a gap: in practice, emergency services sometimes lacked the right information during incidents because a product reached the market via a distributor in another country, or under a different name, without a matching notification.
When does the notification obligation apply?
The new obligation does not apply to every product, but specifically when a distributor places a hazardous mixture on the market in one of three situations: cross-border distribution to an EU member state other than the one for which the supplier has already notified, relabelling where the supplier’s label is replaced or amended, or sale under the distributor’s own brand or trade name. If the supplier has already included both the export countries and the distributor’s trade or brand names in its ECHA notification, an exemption applies and the distributor does not need to submit its own notification.
What should companies do now?
Prebes advises companies to map out, before 1 January 2027, which products they resell to other EU countries or place on the market under their own name, and then to ask their suppliers to extend existing notifications with the correct target markets and product names. If a supplier does not cooperate, the distributor must prepare its own notification in good time via the ECHA systems; the agency provides guidance on this on its “Steps for industry” page. ECHA published the clarification on 14 September 2026.
Context
The obligation builds on Annex VIII of the CLP Regulation, which has applied on a phased basis since 1 January 2021 and harmonises the content and format of PCN notifications across the EU. A pilot study by the ECHA Enforcement Forum found that, in a sample of products, 19 percent were not linked to a valid PCN notification and 15 percent lacked the mandatory UFI code on the label; in more than a third of the cases with a missing notification, the responsibility lay with the distributor rather than the manufacturer. These findings gave ECHA the direct impetus to clarify the role of distributors.
This is relevant for HSE professionals outside Belgium because it concerns an EU regulation that applies directly in all member states: any company that distributes, relabels or sells hazardous mixtures under its own name within the Union — regardless of where it is established — can potentially fall under this notification obligation. Companies that distribute chemical products internationally would do well to check the notification status of their own portfolio now, before the new obligation takes effect on 1 January 2027.
Source: Verplichting voor distributeurs van gevaarlijke stoffen treedt in werking op 1 januari 2027, 22 October 2026
Additional research: ChemLinked – ECHA clarifies distributors’ poison centre notification duties ahead of 2027, HSA Ireland – Poison Centre Notification
