Export notifications for dichloropropene
Dear European Chemicals Agency,
Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting:
Copies of all export notifications filed for 1,3-dichloropropene, and all mixtures containing dichloropropene between January 1 2020 and November 4 2025.
For each notification, I request the non-confidential information, including at minimum:
- Exporter name and address
- Active substance or mixture name and CAS number
- Destination country
- Name of importer
- Name of exporter
- Quantity or mass to be exported
- Proposed date of shipment / year of notification
- Regulatory status notes
If any part of the requested information is considered commercially confidential, please provide a redacted or aggregated version, indicating the legal basis for any redactions.
All the best,
Mathilde Augustin
Dear Ms. Augustin,
Thank you for your below message dated 4 November 2025.
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, which has been registered on 5
November 2025 under reference ATD/114/2025.
Best regards,
ECHA Access to documents team [2]A blue and black logo
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Dear Ms. Augustin,
We refer to your request for access to documents under Regulation (EC) No
1049/2001 (the “ATD Regulation”) registered on 5 November 2025 under
reference ATD/114/2025.
In your request you seek access to “copies of all export notifications
filed for 1,3-dichloropropene, and all mixtures containing dichloropropene
between January 1 2020 and November 4 2025”.
In particular, you seek access to the following information contained in
the concerned export notifications:
“- Exporter name and address
- Active substance or mixture name and CAS number
- Destination country
- Name of importer
- Name of exporter
- Quantity or mass to be exported
- Proposed date of shipment / year of notification
- Regulatory status notes”.
Before being able to process your request and in accordance with Article
6(2) of the ATD Regulation, we would like to clarify certain aspects. Once
clarified, we would also like to discuss the scope of your request. In
order to facilitate such discussion, we propose to organise a
teleconference.
Could you kindly indicate which timeslot would be convenient for you for a
teleconference in Microsoft Teams:
• 10 November 2025 (Monday) at 14:00 Helsinki time (EET)
• 11 November 2025 (Tuesday) at 10:00 Helsinki time (EET)
• 12 November 2025 (Wednesday) at 13:30 Helsinki time (EET)
Should you have a preference for another day, please do not hesitate to
inform us.
Please note that, as set out in the Management Board decision on the
implementation of Regulation (EC) No 1049/2001 in ECHA ([1]MB/12/2008
final), the deadline for replying to your request will run only from the
time we have received your clarification.
We would appreciate receiving your feedback on your availability for a
teleconference as soon as possible.
We thank you for your cooperation.
Best regards,
ECHA Access to documents team [3]A blue and black logo
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medium confidenceP.O. Box 400, FI-00121
Helsinki, Finland
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delete the message.
From: ECHA ATD <[ECHA request email]>
Sent: Wednesday, November 5, 2025 10:41 AM
To: [FOI #16518 email]
Cc: ECHA ATD <[ECHA request email]>
Subject: Acknowledgement of receipt – ATD/114/2025
Dear Ms. Augustin,
Thank you for your below message dated 4 November 2025.
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, which has been registered on 5
November 2025 under reference ATD/114/2025.
Best regards,
ECHA Access to documents team [9]A blue and black logo
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echa.europa.eu
[8]A black background with a black square
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medium confidenceP.O. Box 400, FI-00121
Helsinki, Finland
EMAS Registered
[10]A black background with a black square
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This e-mail, including any files, is intended for the use of the
individual to whom it is addressed. If you have received this
message in error, please notify the author as soon as possible and
delete the message.
Dear Ms. Augustin,
We refer to your request for access to documents under Regulation (EC) No
1049/2001 (the “ATD Regulation”) registered on 5 November 2025 under
reference ATD/114/2025.
This is a kind reminder in relation to ECHA’s invitation to clarify and
discuss your request that was sent to you on 6 November 2025.
Could you kindly confirm receipt of our below message and inform us
whether you are available for a teleconference?
Thank you in advance for your cooperation.
Best regards,
ECHA Access to documents team [2]A blue and black logo
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European Chemicals Agency generated
echa.europa.eu
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medium confidenceP.O. Box 400, FI-00121
Helsinki, Finland
EMAS Registered
[3]A black background with a black square
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message in error, please notify the author as soon as possible and
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From: ECHA ATD <[ECHA request email]>
Sent: Thursday, November 6, 2025 6:20 PM
To: [FOI #16518 email]
Cc: ECHA ATD <[ECHA request email]>; ECHA PIC
<[email address]>
Subject: Proposal for a teleconference – ATD/114/2025
Dear Ms. Augustin,
We refer to your request for access to documents under Regulation (EC) No
1049/2001 (the “ATD Regulation”) registered on 5 November 2025 under
reference ATD/114/2025.
In your request you seek access to “copies of all export notifications
filed for 1,3-dichloropropene, and all mixtures containing dichloropropene
between January 1 2020 and November 4 2025”.
In particular, you seek access to the following information contained in
the concerned export notifications:
“- Exporter name and address
- Active substance or mixture name and CAS number
- Destination country
- Name of importer
- Name of exporter
- Quantity or mass to be exported
- Proposed date of shipment / year of notification
- Regulatory status notes”.
Before being able to process your request and in accordance with Article
6(2) of the ATD Regulation, we would like to clarify certain aspects. Once
clarified, we would also like to discuss the scope of your request. In
order to facilitate such discussion, we propose to organise a
teleconference.
Could you kindly indicate which timeslot would be convenient for you for a
teleconference in Microsoft Teams:
• 10 November 2025 (Monday) at 14:00 Helsinki time (EET)
• 11 November 2025 (Tuesday) at 10:00 Helsinki time (EET)
• 12 November 2025 (Wednesday) at 13:30 Helsinki time (EET)
Should you have a preference for another day, please do not hesitate to
inform us.
Please note that, as set out in the Management Board decision on the
implementation of Regulation (EC) No 1049/2001 in ECHA ([7]MB/12/2008
final), the deadline for replying to your request will run only from the
time we have received your clarification.
We would appreciate receiving your feedback on your availability for a
teleconference as soon as possible.
We thank you for your cooperation.
Best regards,
ECHA Access to documents team [9]A blue and black logo
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European Chemicals Agency generated
echa.europa.eu
[8]A black background with a black square
Description automatically generated with
medium confidenceP.O. Box 400, FI-00121
Helsinki, Finland
EMAS Registered
[10]A black background with a black square
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ISO 9001:2015 medium
certified confidence[11][IMG][12][IMG][13][IMG]
ISO 14001:2015
certified
This e-mail, including any files, is intended for the use of the
individual to whom it is addressed. If you have received this
message in error, please notify the author as soon as possible and
delete the message.
From: ECHA ATD <[14][ECHA request email]>
Sent: Wednesday, November 5, 2025 10:41 AM
To: [15][FOI #16518 email]
Cc: ECHA ATD <[16][ECHA request email]>
Subject: Acknowledgement of receipt – ATD/114/2025
Dear Ms. Augustin,
Thank you for your below message dated 4 November 2025.
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, which has been registered on 5
November 2025 under reference ATD/114/2025.
Best regards,
ECHA Access to documents team [18]A blue and black logo
Description automatically
European Chemicals Agency generated
echa.europa.eu
[17]A black background with a black square
Description automatically generated with
medium confidenceP.O. Box 400, FI-00121
Helsinki, Finland
EMAS Registered
[19]A black background with a black square
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ISO 9001:2015 medium
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This e-mail, including any files, is intended for the use of the
individual to whom it is addressed. If you have received this
message in error, please notify the author as soon as possible and
delete the message.
Dear Ms. Augustin,
We refer to your request for access to documents under Regulation (EC) No
1049/2001 (the “ATD Regulation”) registered on 5 November 2025 with
reference ATD/114/2025.
Since we have not received a reply from you following our proposal for a
teleconference, we will address below the points we wanted to discuss
regarding your request for access to documents.
Summary of your request
In your request, you seek access to “Copies of all export notifications
filed for 1,3-dichloropropene, and all mixtures containing dichloropropene
between January 1, 2020 and November 4, 2025”. We understand that the
reference is made to the export notifications submitted in accordance with
Regulation (EU) 649/2012 (the PIC Regulation) with an intended export date
between 1 January 2020 and 4 November 2025.
In your request, you indicate that you are specifically interested in the
following information contained in the export notifications:
• Exporter name and address
• Active substance or mixture name and CAS number
• Destination country
• Name of importer
• Name of exporter
• Quantity or mass to be exported
• Proposed date of shipment / year of notification
• Regulatory status notes
Based on the above-mentioned criteria ECHA has identified approximately
380 export notifications originating from 14 legal entities falling within
scope of your request.
Requested information
We understand that your request covers the following information contained
in the concerned export notifications:
• Importing party (i.e. importing non-EU country)
• Substance identity:
• Annex I chemical name (i.e. common name)
• CAS number
• If exported as a mixture:
• Mixture name/trade name;
• Expected yearly amount of exported substance or mixture (kg/l per
year)
• Exporter name and address
• Importer name and address
• The expected date of first export. This section also contains the year
of intended export.
We also understand that “regulatory status notes” refers to the use
category for which the final regulatory action was taken for the substance
on ECHA dissemination website. Please note that this information is made
publicly available. You can find the relevant information for the
substance 1,3-dichloropropene via the following link: [1]Chemicals subject
to PIC - ECHA. Please let us know if this publicly available information
does not address this point of your request and clarify which point of
Annex 2 of the PIC Regulation falls within the scope of your request.
In addition to these elements, we also suggest including the concentration
(%) of the Annex I chemical(s) in the mixture for clarity reasons. This
will allow you to get the full picture on the amount of substance subject
to the export notification.
Proposal for a fair solution (scope, format, timeline)
Scope of your request
Given the large number of export notifications which need to be processed
as well as third-parties from whom the documents originate (i.e. concerned
exporting companies) which would need to be consulted in accordance with
Article 4(4) of the ATD Regulation, the processing of your request cannot
be carried out within the normal time limits set out in Article 7 of ATD
Regulation.
Article 6(3) of the ATD Regulation provides that in the event of an
application relating to a very long document or to a very large number of
documents, the institution concerned may confer with the applicant
informally, with a view to finding a fair solution. You will find below a
list of elements that can be taken into consideration for the purpose of
finding a fair solution.
Format of the document
In your request, you mention that you would like to receive copies of the
export notifications at issue. However, since you are interested in
specific information contained in these export notifications and in order
to facilitate the processing of your application, please confirm whether
you would agree to limit your request to a single document containing the
information from the export notifications directly extracted from the ePIC
database.
If you agree to receive an extract of the information of interest to you,
we would like to inform you that, the name and address of the importer(s)
cannot be extracted from ECHA’s database. Therefore, in order to include
this information in the scope of your request ECHA would still need to
process each export notification individually. Furthermore, the disclosure
of this information, linked to the information on the exporter, might
reveal links in the supply chain which are deemed confidential in
accordance with Article 118(2)(d) of Regulation (EC) No 1907/2006 (“the
REACH Regulation”). In light of the above and with the view to finding a
fair solution, we would kindly ask you to consider withdrawing this point
of your request.
Timeline
ECHA is committed to treat requests under the ATD Regulation within the
shortest timeframe possible.
Based on our preliminary assessment, certain information extracted from 89
export notifications falling under the scope of your request has already
been disclosed or partially disclosed to other applicants in the context
of previous requests for access to documents. These documents can be
provided to you by 26 November 2025.
Nevertheless, your application still covers a very large number of
documents (around 290) originating from third parties (14), which have not
been disclosed in the context of previous requests for access to documents
and therefore, will need to be assessed individually.
Consequently, and taking into account the processing of your request as an
extract of the requested information, the processing time of your request
is estimated at 6 months starting from the day when the scope of the
request is confirmed by you. If your request covers the export
notifications as a whole, due to its extensive scope and the workload
required to process these documents in their entirety, we would need to
re-assess the processing time of your request based on a reduced scope as
discussed below.
Please note that the assessment of this timeline takes into account the
ECHA end of year office closure, and the heavy ongoing workload affecting
the team processing your request (i.e. processing of end-of-year peak of
submission of export notifications and other ongoing ATD requests).
If you wish to receive a reply covering some of the information of
interest to you before the above-mentioned timeframe, or if your request
covers the export notifications as a whole, we propose to discuss the
following points:
• Reducing the scope of your request. This reduction may, inter alia, be
based on the following criteria:
• Specific importing/exporting countries of interest to you;
• Further selection of years of intended export.
• Process your request in batches based on an order of priority
indicated by you (e.g. exporting countries or companies with the
highest number of export notifications first).
We would appreciate receiving your feedback as soon as possible and, in
any event, by Wednesday 19 November 2025.
We thank you for your time and cooperation.
Best regards,
ECHA Access to documents team [3]A blue and black logo
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medium confidenceP.O. Box 400, FI-00121
Helsinki, Finland
EMAS Registered
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From: ECHA ATD <[ECHA request email]>
Sent: Monday, November 10, 2025 2:32 PM
To: [FOI #16518 email]
Cc: ECHA PIC <[email address]>; ECHA ATD
<[ECHA request email]>
Subject: RE: Proposal for a teleconference – ATD/114/2025
Dear Ms. Augustin,
We refer to your request for access to documents under Regulation (EC) No
1049/2001 (the “ATD Regulation”) registered on 5 November 2025 under
reference ATD/114/2025.
This is a kind reminder in relation to ECHA’s invitation to clarify and
discuss your request that was sent to you on 6 November 2025.
Could you kindly confirm receipt of our below message and inform us
whether you are available for a teleconference?
Thank you in advance for your cooperation.
Best regards,
ECHA Access to documents team [9]A blue and black logo
Description automatically
European Chemicals Agency generated
echa.europa.eu
[8]A black background with a black square
Description automatically generated with
medium confidenceP.O. Box 400, FI-00121
Helsinki, Finland
EMAS Registered
[10]A black background with a black square
Description automatically generated with
ISO 9001:2015 medium
certified confidence[11][IMG][12][IMG][13][IMG]
ISO 14001:2015
certified
This e-mail, including any files, is intended for the use of the
individual to whom it is addressed. If you have received this
message in error, please notify the author as soon as possible and
delete the message.
From: ECHA ATD <[14][ECHA request email]>
Sent: Thursday, November 6, 2025 6:20 PM
To: [15][FOI #16518 email]
Cc: ECHA ATD <[16][ECHA request email]>; ECHA PIC
<[17][email address]>
Subject: Proposal for a teleconference – ATD/114/2025
Dear Ms. Augustin,
We refer to your request for access to documents under Regulation (EC) No
1049/2001 (the “ATD Regulation”) registered on 5 November 2025 under
reference ATD/114/2025.
In your request you seek access to “copies of all export notifications
filed for 1,3-dichloropropene, and all mixtures containing dichloropropene
between January 1 2020 and November 4 2025”.
In particular, you seek access to the following information contained in
the concerned export notifications:
“- Exporter name and address
- Active substance or mixture name and CAS number
- Destination country
- Name of importer
- Name of exporter
- Quantity or mass to be exported
- Proposed date of shipment / year of notification
- Regulatory status notes”.
Before being able to process your request and in accordance with Article
6(2) of the ATD Regulation, we would like to clarify certain aspects. Once
clarified, we would also like to discuss the scope of your request. In
order to facilitate such discussion, we propose to organise a
teleconference.
Could you kindly indicate which timeslot would be convenient for you for a
teleconference in Microsoft Teams:
• 10 November 2025 (Monday) at 14:00 Helsinki time (EET)
• 11 November 2025 (Tuesday) at 10:00 Helsinki time (EET)
• 12 November 2025 (Wednesday) at 13:30 Helsinki time (EET)
Should you have a preference for another day, please do not hesitate to
inform us.
Please note that, as set out in the Management Board decision on the
implementation of Regulation (EC) No 1049/2001 in ECHA ([18]MB/12/2008
final), the deadline for replying to your request will run only from the
time we have received your clarification.
We would appreciate receiving your feedback on your availability for a
teleconference as soon as possible.
We thank you for your cooperation.
Best regards,
ECHA Access to documents team [20]A blue and black logo
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European Chemicals Agency generated
echa.europa.eu
[19]A black background with a black square
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medium confidenceP.O. Box 400, FI-00121
Helsinki, Finland
EMAS Registered
[21]A black background with a black square
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ISO 14001:2015
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message in error, please notify the author as soon as possible and
delete the message.
From: ECHA ATD <[25][ECHA request email]>
Sent: Wednesday, November 5, 2025 10:41 AM
To: [26][FOI #16518 email]
Cc: ECHA ATD <[27][ECHA request email]>
Subject: Acknowledgement of receipt – ATD/114/2025
Dear Ms. Augustin,
Thank you for your below message dated 4 November 2025.
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, which has been registered on 5
November 2025 under reference ATD/114/2025.
Best regards,
ECHA Access to documents team [29]A blue and black logo
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European Chemicals Agency generated
echa.europa.eu
[28]A black background with a black square
Description automatically generated with
medium confidenceP.O. Box 400, FI-00121
Helsinki, Finland
EMAS Registered
[30]A black background with a black square
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ISO 9001:2015 medium
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ISO 14001:2015
certified
This e-mail, including any files, is intended for the use of the
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message in error, please notify the author as soon as possible and
delete the message.
Dear Ms Augustin,
Please find attached the final reply to your ATD request (Ref.
ATD/114/2025) signed by Ms Audrey Anne Anastasi, Head of Submission and
Processing Unit.
This communication is sent to you by email only. Could you please confirm
the receipt of this email and the documents attached to it?
Kind regards,
Valeria Yilmaz
PIC Operations Team
Submission and Processing Unit
[1][email address]
echa.europa.eu
P.O. Box 400, FI-00121
Helsinki,
Finland
EMAS Registered
[2][IMG][3][IMG] [4][IMG] [5][IMG] [6][IMG]
ISO 9001:2015 certified
ISO 14001:2015 certified
The above represents the opinion of the author and is not an official
position of the European Chemicals Agency. This email, including any
files attached to it, is intended for the use of the individual to whom it
is addressed. If you have received this message in error, please notify
the author as soon as possible and delete the message.
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