Applies for: iPublisher
Where: PCN > SDS sections 1, 2, 3, 9, 11 / Properties > PCN / ECHA legal entities

Why PCN data isn't all in one place

PCN was added on top of iPublisher's existing SDS authoring structure. That has one practical consequence worth knowing up front: PCN data isn't all in one place. Some of it is already sitting in your SDS, some of it lives in a dedicated PCN section, and a small but essential piece lives outside the product record entirely, in your legal entity setup.

SDS authoring is also built around free text, while PCN and IUCLID expect standardised, structured values — fixed picklists, specific number formats, exact wording. iPublisher bridges the two by mapping your SDS content into the structured PCN fields and validating everything before it lets you publish or export.

The practical takeaway: keep your SDS data clean, fill in the PCN-only fields, configure your legal entity exactly right, and then publish a PCN snapshot.

Where each piece of PCN data comes from

There are three data sources feeding a PCN dossier:

1. SDS sections 1, 2, 3, 9, and 11 — most of the substantive content
2. The PCN accordion under Properties — PCN-specific fields that don't belong in a standard SDS
3. The ECHA legal entity page — who is submitting, and their official identity

Here's the full map:

Six things worth knowing before you start

These cover most of the recurring questions and support cases:

• Colour — Colour itself comes from Section 9; colour intensity is set in the PCN box. Free-text colours have to match ECHA's standard English colour names, or they can be silently dropped from the dossier.
• pH — The pH value is entered in Section 9; the pH concentration and the "not available" reason are set in the PCN box. pH must be entered as a Number or an Interval — no other formats are accepted.
• Physical form — The Form field in Section 9 drives both the general physical state and the more detailed IUCLID form. If Form is left empty, validation will block you.
• UFI — Lives in Section 1. Generation uses the supplier identifier together with the formulation number, so both need to be correct before you generate one.
• Concentration ranges — Ranges entered in Section 3 need directional qualifiers on both bounds. Approximate qualifiers like "ca." are not accepted.
• Substance names — The English name is used first, to keep the IUCLID identity stable. A missing English name triggers a warning (you may see it referenced as QLT635).

How validation works

Validation happens at three separate checkpoints, and it's worth knowing the difference between them:

1. The "Validate PCN" button — This is advisory. It checks your data before publishing, but it never changes anything for you.
2. The publish gate — Before you can publish, "Validate and prepare PCN" must be ticked. At this point, errors block publishing, but warnings do not.
3. The export dialog — This validates against the specific notification type you're exporting. Any remaining errors will disable the download button.

What errors and warnings typically relate to:

• Product information — name, colour/physical state, UFI, use type, main intended use, packaging
• Mixture composition — composition present, usable identifiers, valid concentration qualifiers, totals not too low or too high
• Classification & labelling — a classification record, signal word, and hazard statements for classified mixtures
• Toxicology / pH — toxicological text, pH value or range, pH concentration, and the pH not-available reason where relevant
• Legal entity — submitter contact fields and email format; a warning appears if no ECHA legal entity is configured
• Markets / languages — a market must be selected, required languages must be present, and note that the UK/GBR market is not accepted by the portal

Warnings don't stop you from publishing, but they're worth taking seriously — they often point to gaps that lead to poor-quality emergency response data, or to review work further down the line.

The workflow: publish first, export second

1. Complete the product data — SDS sections, the PCN box, and the legal entity setup.
2. Validate and prepare PCN — tick the checkbox and choose the submission profile.
3. Publish a snapshot — this is important: the export step reads from the frozen, published snapshot, not from whatever is currently in the editor.
4. Open the IUCLID export tab — select the published row and click PCN.
5. Download the .i6z file — review it in IUCLID, then send it manually to ECHA Submission Portal.
   
   

If you edit a product after publishing, remember to publish again before exporting — otherwise the export will still reflect the older snapshot.

Choosing the right notification type

When you export, iPublisher pre-selects a notification type based on your publish history — but you can override it. The three types are:

• Initial notification — the first notification for this product; no extra fields appear in the export dialog.
• Update — for revising an existing notification. This requires a reason for the update, and some reasons will open additional market/country panels.
• New notification after significant composition change — used when the composition has changed enough to require a new PCN. The previous PCN number is mandatory in this case.
  
  

Keep in mind that iPublisher's auto-detection is advisory: it's based on previous PCN numbers found in published snapshots, not on your live editor data or on the actual submission status at ECHA.

Quick troubleshooting reference