On 12 August 2026, Delegated Regulation (EU) 2026/1278 was published. This amends and rectifies Regulation (EU) No 649/2012, better known as the PIC Regulation. Various pesticides and industrial chemical substances are added to or moved within the annexes of this regulation.
The regulation came into force on 1 September 2026. The changes apply from 1 October 2026. Do you work with hazardous chemical substances? Then it is important to check whether any of the substances your organization works with are on the amended lists.
The PIC Regulation governs the import and export of certain hazardous chemical substances between the European Union and countries outside the EU. With Delegated Regulation (EU) 2026/1278, the substance lists are adjusted to new European and international decisions on the use of and trade in these substances.
These changes concern both pesticides and industrial chemical substances.
Various plant protection products and biocides are added to or moved within Annex I. These include:
- carbendazim;
- metribuzin;
- dodemorph, including dodemorph acetate;
- fenpyrazamine;
- flumetralin;
- metaflumizon;
- pyridalyl;
- tritosulfuron;
- PHMB (1600;1.8).
In addition, existing listings of abamectin, carbosulfan, fenthion and terbufos are amended.
For carbosulfan and certain highly concentrated formulations with fenthion, the way international trade is regulated also changes. These substances are included in part 3 of Annex I. As a result, they fall under the prior informed consent procedure, also called the PIC procedure. In short, this means that the country to which the substance is exported makes a prior decision on the import.
Several industrial chemical substances are also added to Annex I. These include:
- certain chromium compounds;
- certain arsenic compounds;
- DEHP;
- DBP;
- trichloroethylene;
- pitch, coal tar, high temperature;
- UV-320;
- UV-327;
- UV-328;
- UV-350;
- certain organotin compounds;
- various other substances and reaction products identified as very concerning under REACH;
- Dechlorane Plus.
Stricter rules apply to UV-328, Dechlorane Plus and methoxychlor. These substances are included in Annex V. This essentially bans export from the EU.
There are exceptions. For example, export may be permitted in certain cases if a specific exemption applies or if the concentration of the substance remains below the threshold value from the POPs Regulation.
The change is especially relevant for organizations that work with one or more of the mentioned substances. Think of companies that produce or use these substances, but also organizations that trade products, mixtures or articles containing these substances with countries outside the EU.
Is Regulation (EU) No 649/2012 in your organization's compliance register? Then this change does not automatically mean you have to take action. The first question is whether your organization actually works with one of the substances whose listing is changing.
Do you work with one of the mentioned substances? Then it is especially important where the substance is listed in the PIC Regulation. That determines which rules apply when trading with countries outside the EU.
Depending on the substance, for example, a notification obligation may apply or the PIC procedure may be applicable. For UV-328, Dechlorane Plus and methoxychlor, an export ban generally applies.
Therefore, the change may affect existing import and export processes, controls and documentation. If you do not work with the substances affected by the change, there are no direct new consequences for your organization based on this change.
Check before 1 October 2026 whether your organization works with any of the substances added, moved or amended by Delegated Regulation (EU) 2026/1278.
If so, then check:
- where the substance is used within your organization;
- whether the substance occurs in products, mixtures or articles your organization works with;
- whether these are traded from or to countries outside the EU;
- where the substance is listed in Annex I or V from 1 October 2026;
- which obligations therefore apply to your organization;
- whether existing procedures and documentation for import or export need to be adjusted.
Pay extra attention to carbosulfan and certain fenthion formulations due to the PIC procedure and to UV-328, Dechlorane Plus and methoxychlor due to the export ban.
Delegated Regulation (EU) 2026/1278 amends a large number of substance listings in the PIC Regulation. Is Regulation (EU) No 649/2012 in your compliance register? Then especially check whether your organization works with one of the amended substances. If not, this change requires no further action.
