Carbosulfan and Fenthion Imports in the EU: What Changes for Importers and Pesticide Manufacturers

Key data

Importers and exporters of pesticides operating with carbosulfan or fenthion face a major regulatory change. The Commission Implementing Decision (EU) 2026/1977, adopted by the Commission on 8 September 2026, establishes the EU's final position regarding future imports of these two active substances in ultra-low volume formulations with a minimum concentration of 640 g/l.

This decision is framed within the Regulation (EU) No 649/2012, the European framework regulating the export and import of hazardous chemicals through the Prior Informed Consent (PIC) procedure. This mechanism requires that importing countries outside the EU be informed and give their consent before receiving certain hazardous substances. The Commission's decision now closes the European side of that equation.

What does this regulation establish?

The decision determines the EU's final response —consent or rejection— to future imports of the following substances and formulations:

The PIC procedure, regulated by Regulation 649/2012, requires the EU to communicate to third countries its position on whether it allows these substances to enter its territory. With this implementing decision, that position is fixed definitively, which has direct consequences for any ongoing or planned commercial operation involving these formulations.

Furthermore, the decision implies obligations for the competent national authorities of each Member State, which are responsible for managing PIC notifications and communicating the European position to economic operators under their jurisdiction.

Economic and operational impact

The impact of this decision is not theoretical: it directly affects the viability of specific commercial operations. The most relevant effects for operators are:

• Review of import contracts: Any existing or negotiated contract contemplating the entry into the EU of carbosulfan or fenthion in ULV formulations with a concentration equal to or greater than 640 g/l must be reviewed in light of this final decision.
• Risk of customs and phytosanitary sanctions: Non-compliance with PIC regulations can result in sanctions both at the border (retention or destruction of goods) and of a phytosanitary nature, according to the regulations of each Member State.
• Impact on the supply chain: Manufacturers of formulated products that depend on these raw materials from third countries must assess whether their current suppliers can continue operating under the new framework.
• Strengthened notification obligations: Competent national authorities will have to manage PIC notifications in accordance with the position now fixed, which may generate new administrative burdens for operators requiring import processing.

Who does it affect?

• Pesticide importers bringing into the EU products containing carbosulfan or fenthion in ultra-low volume (ULV) formulations with a minimum concentration of 640 g/l.
• European exporters of these substances to third countries, who must comply with PIC notification requirements in both directions.
• Manufacturers and formulators of pesticides using carbosulfan or fenthion as active substances in their products.
• Distributors and traders of plant protection products intermediating in international trade operations with these substances.
• Competent national authorities responsible for managing PIC notifications in each EU Member State.
• Foreign trade advisors and regulatory compliance consultants advising companies in the agrochemical sector.

Practical example

Imagine a Spanish plant protection product distributor that has contracted the import of a ULV formulated insecticide containing carbosulfan at 70% (equivalent to 700 g/l of active substance) from a supplier in a third country.

With the entry into force of Decision 2026/1977, that operation is directly affected: the concentration exceeds the 640 g/l threshold that triggers the application of PIC regulations. The company must verify whether the final position set by the EU implies a rejection of that import or establishes specific conditions. If the operation is executed without verifying the official position, the goods may be retained at customs and the company exposed to phytosanitary sanctions. The first step is to contact the competent national authority to confirm the status of the PIC notifications associated with that operation.

What should companies do now?

1. Audit your product catalog: Identify whether any of the products you import, export or manufacture contains carbosulfan or fenthion in ULV formulations with a concentration equal to or greater than 640 g/l.
2. Review contracts and ongoing operations: Halt or review any import operation with these substances until confirming whether the EU's final position allows or restricts that specific import.
3. Contact the competent national authority: In Spain, the body responsible for managing PIC notifications is the Ministry of Agriculture, Fisheries and Food. Verify the status of your notifications.
4. Consult the full text of Decision 2026/1977: Access the official source on EUR-Lex to know the exact scope of the final position set (consent or rejection).
5. Update internal compliance procedures: Incorporate this decision into the control protocols for imports and exports of plant protection products.
6. Seek advice on sanction risk: If there are operations already executed that may be in conflict with this regulation, consult with a specialist in foreign trade and phytosanitary regulations to assess exposure to customs sanctions.

Official source

Consult complete regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601977