Great Britain Adds New PIC, POPs And Mercury-Product Export Controls

GB PIC Export Controls Now Cover Additional Chemicals

The revised Part 3 list adds decabromodiphenyl ether, known as decaBDE, perfluorooctanoic acid (PFOA), its salts and related compounds, terbufos, carbosulfan and fenthion formulations at or above 640 grams of active ingredient per litre. Part 3 chemicals are subject to export notification and the Rotterdam Convention PIC procedure, including the importing country's response.

Carbosulfan and qualifying fenthion formulations move from Part 2 to Part 3, rather than becoming newly controlled from scratch. DecaBDE and PFOA also enter Part 1 because their industrial uses are severely restricted.

Part 4, which covers persistent organic pollutants subject to export bans, now includes dicofol, pentachlorophenol and its salts and esters, PFOA, perfluorooctane sulfonic acid, perfluorohexane sulfonic acid, methoxychlor and decaBDE. The list preserves specific exemptions or derogations available under Article 4 or Annex I of the assimilated POPs Regulation.

Exporters must therefore assess the precise substance, concentration, use and exemption before stopping or releasing a shipment.

Mercury-Product Export Bans Extend Across Manufacturing Sectors

Part 5 now prohibits exports of specified mercury-added products. These include compact fluorescent lamps, cold cathode and external electrode fluorescent lamps for electronic displays, batteries containing more than 0.0005% mercury by weight, certain switches and relays, specified cosmetics, pesticides, biocides, topical antiseptics and non-electronic measuring devices.

The list also covers strain gauges, melt-pressure devices, some pumps, tyre balancers and wheel weights, photographic film and paper, and mercury used as satellite propellant. Exemptions remain for civil-protection and military uses, research, instrument calibration and reference standards, and replacement components where no feasible mercury-free alternative exists.

What Changed And What Remains Unchanged

The new trigger is the operative list revision, not a consultation. Existing GB PIC mechanics continue: notification is generally due at least 35 days before the first export in a calendar year to each importing country, explicit consent may be required, and annual quantities are reportable by 31 March.

The research and analysis exclusion of no more than 10 kilograms per exporter, per year and importing country also remains available where its conditions are met.

Several substances appear in more than one list part, so screening only by chemical name can produce the wrong answer. Export decisions should combine substance identity with product form, concentration, intended use, destination and the applicable exemption evidence.

Practical Stakeholder Actions

Rescreen export catalogues and bills of material against all five list parts. Hold affected shipments until notification, consent or exemption evidence is complete. Product manufacturers should obtain mercury and persistent organic pollutant declarations from suppliers, while customs and logistics teams should update stop codes and escalation routes. Preserve records for the next annual quantity report.