PCN deadlines: 2021, 2024, 2025 — and where you stand in 2026

Annex VIII rolled out in stages rather than on a single date, and a great deal of guidance written during that rollout still talks about the deadline as something still to come. That is no longer accurate: the final phase-in date, 1 January 2025, is now in the past, and market surveillance authorities are treating every unnotified mixture the same way regardless of its history — it makes no difference to them whether a product simply skipped notification altogether or once relied on a transitional allowance that has since expired.

The three dates

Three dates define the rollout, each tied to how the mixture is used rather than to when your company happened to start selling it.

Two things about this schedule catch companies out. First, the dates are use-based, not product-based: the same formulation sold to both a retail customer and a factory can sit in two different deadline bands depending on the channel. Second, the three dates are not alternatives to choose from — a mixture that was in scope from 2021 did not get a second chance at compliance in 2024 or 2025, it was simply already overdue.

The transitional period is over

The 2025 date is the one most worth being precise about, because it is the deadline most competing guidance still describes as upcoming. It is not. The transitional period existed for one reason: to let companies keep selling a mixture that had already been notified under a member state's own pre-Annex-VIII scheme, without forcing an immediate re-submission the moment the harmonised format took effect. That allowance had a fixed expiry, and the expiry was 1 January 2025.

From that date, an old national notification — however correctly it was filed at the time, and however long it had been accepted by a member state's poison centre — stops being sufficient on its own. It does not carry any residual legal weight for a mixture placed on the market today. What replaces it is exactly what Annex VIII has required of every other mixture since 2021 or 2024: a PCN dossier in the harmonised format, built around a UFI, submitted through the ECHA Submission Portal to every member state the mixture reaches.

This matters most for products that have not changed in years. A formulation that has sat quietly on national notification since before Annex VIII existed, with no reformulation and no reason for anyone to revisit its paperwork, is now out of compliance purely because the calendar moved — not because anything about the product itself changed.

If your mixture is on the market and not notified

If you have read the table above and recognised your own product in it, the position is straightforward to describe, even if it is not comfortable: the mixture is currently on the EU market without the notification Annex VIII requires. That is a compliance gap, not a paperwork delay, and it does not close itself.

The practical route out of it runs in a fixed order:

1. Confirm the classification. Annex VIII obligations follow from the mixture's CLP classification for health or physical hazards — the dossier requirement, and how urgent it is, depends on getting this right first.
2. Establish who holds the duty. The obligation sits with whichever company places the mixture on the EU market, which is not always the company holding the formulation. See our page on who must submit a PCN if more than one company touches this product before it reaches a customer.
3. Assemble the composition and toxicological data the dossier needs, generate the UFI, and build the submission in IUCLID.
4. Submit through the ECHA Submission Portal to every member state where the mixture is placed on the market, then update the label with the UFI once the dossier is accepted.

What this does not do is erase the period the mixture spent on the market unnotified. National authorities enforce Annex VIII, not ECHA, and what happens if the gap is discovered before you close it — market withdrawal, customs holds, the range of penalties member states can apply — is covered in full on our page on what happens if you do not notify. If the fastest route to a submitted dossier matters more than working through the sequence yourself, that is exactly what we handle; see our UFI and PCN services for how the process runs when we run it.

Deadlines for changes

A submitted PCN dossier is not a one-time filing that then sits untouched for the life of the product. Once a mixture is notified, certain changes to it — a new trade name, a composition shift beyond the declared concentration range, a different EuPCS product category, a revised classification, new toxicological information — trigger a duty to update the dossier, and that update has its own deadline running from the date of the change, separate from the three dates above.

This is where a lot of otherwise-compliant companies drift out of compliance without a single new product launch: the original 2021, 2024 or 2025 deadline was met correctly, then a supplier substitution or a rebrand shifted the composition or the trade name, and the update never followed. The dossier on file stops matching the product on the shelf, which defeats the purpose of having a dossier at all — a poison centre working from a UFI expects the record behind it to be current. The full list of what counts as an update trigger, and how long you have to act on each one, is set out on our page on when a PCN update is required.