EU consultation
15 submissions from 13 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 16 submissions on this file. Shown here: the 15 from organizations. Not shown: 1 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. About this data →
14 submissions from industry and none from civil society organizations; 1 from public authorities, academia and others.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice.
The file, right now
The consultation closed on 21 Aug 2026; it ran from 24 Jul 2026.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Reg del.
Showing 15 of 15 submissions.
· · filed 21 Aug 2026 · source
Cefic's Oxygenated Solvents Producers Association (OSPA), part of the European Solvents Industry Group (ESIG), and the BDO & Derivatives Sector Group welcome the opportunity to comment on the draft Commission Delegated Regulation amending Annexes I and V to Regulation (EU) No 649/2012.
The proposed inclusion of boric acid as well as borate salts into annex I part 1 does not serve the purpose of PIC Regulation. There are no expected benefits as all products potentially affected by an export notification are already assessed as safe in handling. Additional burdens for fertilizer producers endanger nutrient supply and thus compromise food security.
· · filed 21 Aug 2026 · source
We support the objectives of Regulation (EU) No 649/2012 and the Rotterdam Convention in promoting transparency in the international trade of hazardous chemicals. However, we would like to express concerns regarding the inclusion of fragrance ingredients such as Lilial within a regulatory framework primarily intended for pesticides and industrial chemicals. Lilial (Cas no.
Bisphenols Europe appreciates the opportunity to comment on the draft Commission Delegated Regulation amending Regulation (EU) No 649/2012 as regards the listing of pesticides and industrial chemicals. We support the objectives of the PIC Regulation and the Rotterdam Convention to promote shared responsibility and informed decision-making in the international trade of hazardous chemicals.
Beitrag zur öffentlichen Konsultation zur Änderung von Anhang I der PIC-Verordnung (EU Nr. 649/2012) Die Aufnahme von Borsäure sowie Natriumboraten ist unnötig und gefährdet die Ernährungssicherheit Die vorgeschlagene Aufnahme von Borsäure sowie Boratsalzen in Anhang I Teil 1 dient nicht dem Zweck der PIC-Verordnung.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CONSULTATION INPUT AUGUST 2026 CASG, a Cefic sector group representing MCCP (medium chain chlorinated paraffins) EU manufacturers, welcomes the opportunity to contribute to the open consultation on the inclusion of substances in the Annexes of Regulation (EU) No 649/2012 concerning the export and import of hazardous chemicals (PIC). The following key points have been identified by the group: 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We wish to comment specifically on the proposed inclusion of 2-methyl-1,2-benzisothiazol-3(2H)-one (MBIT), CAS No 2527-66-4, in Annex I. We respectfully request that the Commission reconsider the proposed inclusion of MBIT.
· · filed 21 Aug 2026 · source
Yara supports the objective of ensuring the safe management of hazardous chemicals and improving transparency in international trade under Regulation (EU) No 649/2012. At the same time, we encourage further assessment of the impact of the proposed amendments on products that contain substances in scope only as minor ingredients and where the associated risk profile differs significantly from that of the pure or…
MedTech Europe, the European trade association for the medical technology industry including diagnostics, medical devices and digital health, welcomes the opportunity to provide feedback on the draft Commission Delegated Regulation amending EU Regulation No 649/2012 on the export and import of hazardous chemicals. Please find our comments and recommendations in the attached document.
· · filed 18 Aug 2026 · source
Aiming for an application date in Q1 / April 2027 continues to place a significant burden on affected companies and authorities. The most recent amendment to the PIC Regulation will apply from 1 October 2026, meaning that export notifications must already be prepared and submitted from August 2026 onwards, including possible waiver submissions in October 2026.
· · filed 14 Aug 2026 · source
Good afternoon, although we are in the process of replacing CAS 71868-10-5, it is present in more than 3000 formulas and for an SME like us we need a similar adaptation time as when a substance is reclassified on the basis of CLP. Kind regards.
Filed in Spanish · English published by the European Commission
Fecc welcomes the opportunity to provide feedback on the European Commissions initiative to amend Annexes I and V to Regulation (EU) No 649/2012 concerning the export and import of hazardous chemicals. Fecc supports the objectives of the PIC Regulation and the EUs commitment to the safe management of chemicals globally, while stressing the need for updates to remain practical, predictable and proportionate for…
Public Consultation Submission Hazardous substances exemption for lead and cadmium in certain electric and electronic components (Ares (2026)6840617) Initiative reference: 14509 Hazardous substances exemption for lead and cadmium in certain electric and electronic components Relevant provision: Draft Annex, Point 2(a) Annex IV, sub-entry 1(b)-III and sub-entry 1(b)-VI Industrial Physics designs and manufactures…
Regarding Annex II of the draft amending regulation (Ares (2026) 7318336) (which refers to Annex V of EU Regulation 649/2012), we encourage you to provide us with support in implementing the regulations by listing CAS numbers in full, rather than concluding them with the phrase and others.
· · filed 28 Jul 2026 · source
Dear Commission, Thank you for inviting feedback. I'm well aware that this is a highly technical regulation with only a few people affected compared with many other EU-Regulations. Nonetheless, I ask you how should any organization involved with the export of chemicals form any opinion? You have to find experts, understand the legal text, do an assessment and get the approval from the higher ups!
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed”. You read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.