ECICS Story

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ECICS Story

• Rachel Harvey-Kelly
• Klaus Daginnus

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Table of Contents

• Customs and Chemistry
• ECICS present
• The ECICS Study
• Regular ECICS Updates
• Preparation of ECICS upgrades e.g. EC 304/2003,
  EEC 67/548
• Substance identification
• Substance customs classification
• Policy support to DG TAXUD and other DGs
• Outlook

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The Customs Laboratories in EU
The 77 EU Customs Laboratories units locations
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The Customs Laboratories in EU
77 Customs Laboratories in EU - 17 states with 1
laboratory, - 7 states with several units (CZ,
DE, EL, ES, FR, IT, PL). All public laboratories,
apart for 2 states, mainly belonging to their
ministry of finance, under the authority of the
Customs Department.
75 of the work is dedicated to Customs and
Excise (in 2003) Principle missions Tariff
nomenclature 44 Tax provisions 19 Common
Agricultural Policy 17 Narcotics
psychotropic drugs 6 Products quality, fraud
detection 4 Consumer Health
3 Environment 2 Other 5
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The Customs Laboratories in EU
2 000 people working for EU Customs
Laboratories Analyst 55 Scientific
advisor 20 Research scientist 8
680 000 samples analysed per year in EU Customs
Laboratories (representing about 1 700
000 determinations) Textile 29
Agricultural products, food 25 Fuels
and petroleum products 12 Chemicals 9
Narcotic psychotropic drugs 9 Wines,
alcohols and brandy 5
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GCL- Action 4 Conferences

• 2nd Conference of European Customs Chemists
• 22-24 October 2003, Prague, Czech Republic

Theme Safeguarding the European citizens and
protecting the environment in the context of
globalisation Attendance 137 participants from
28 countries
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GCL the future
GCL next main event
3rd European Customs Chemists Conference Athens,
Greece, April 2007 Theme The role of customs
control in facilitating trade and
guaranteeing safety and security
GCL aim for the future

• Pursue the effort towards a network of Customs
  Laboratories
• Common work and harmonised procedures for a
  uniform
• application and realisation of Customs duties
• Better use of the human and technical resources
• Exchange of expertise creation of centres of
  excellence
• Accompanying the Customs Laboratories evolution
• Safeguard of citizens, environment protection,
  fight against
• counterfeiting and fraud, fight against
  terrorism

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The European Customs Inventory of Chemical
Substances
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The ECICS Story

• Created by DG TAXUD in 1970
• To ease customs clearance and control and to
  prepare legislation and trade agreements
• First edition in 1974
• Lists about 28 600 chemicals( ? 35 400 chemical
  names) mainly pure chemicals
• In particular pharmaceuticals, pesticides,
  chemical weapons, narcotic drugs, precursors,
  ozone-depleting substances, other controlled
  substances or of commercial interest

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Present ECICS

• International names IUPAC, ISO, INN, CI
• Customs classification HS and CN codes
• CAS number and CUS number
• In 11 EU languages
• Translation module for IUPAC names
• Free on line on DG TAXUD DDShttp//europa.eu.int/
  comm/taxation_customs/dds/en/home.htm
• Used worldwide (HS gt 98 of international trade)

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Question Who are you?
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QuestionWhat information are you interested in?
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Questionnaire Are you interested in a
particular piece of legislation?
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ECICS Study

• Technical / Scientific Support to DG TAXUD with
  regard to products of the chemical or allied
  industries
• ECICS Updates
• ECICS upgrades
• Identifying new products and proposing
  introduction
• International / EC legislation on chemical
  substances
• ECICS quality measures
• Recommendations to the ECICS redesign

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ECICS / ECB overlap
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ECICS overlap other EU regulations
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ECICS overlap / others
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ECICS updates

• 1st update
• EC 1789/2003, amending EEC 2658/87 A total of
  117 code changes concerning approximately 11.400
  chemicals were performed
• 2nd update
• EC 1810/2004, amending EEC 2658/87
• 3rd update
• EC 1719/2005, amending EEC 2658/87
• Adding CAS-RN to the substances, which had no CAS
  assigned
• Data exchange ECICS / ChemDat Merck
• External error messages
• 4th update
• EC xxxx/xxxx, amending EEC 2658/87 implementation
  of HS 2007

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ECICS upgrade workflow
Inventory
Preparatory work
Substance Identification
Names, structure, ID
Substance Customs classification
HS, CN
Review by TAXUD, MS, Int. Org.
ECICS upgrade
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Substance Identification and Classification for
ECICS
Why we classify For tariff imposition, for
measurement, for control What we
classify Individual chemical substances and
preparations, pharmaceuticals, pesticides,
chemical weapons, waste, colouring materials, and
products allied to the chemical industry

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The Classification System The Harmonised System
a global system under the management of the World
Customs Organisation which provides a
classification system for all traded goods. It
classifies using a 6 digit system The Combined
Nomenclature System - under the legislation of
the European Commission, updated and published
once a year in the OJ. It classifies all traded
goods under an 8 digit code, the first 6 of which
are taken from the Harmonised System (HS)
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Chemicals in the Combined Nomenclature (CN)
system ECICS substances are found in the
following chapters 11 Products of the Milling
Industry 15 Animal or Vegetable Fats and
Oils 17 Sugars and Sugar Confectionary 22
Beverages, Spirits, Vinegar 25 Salt, Sulphur,
Earth and Stone 26 Ores, Slag and Ash 27
Mineral fuels, Mineral Oils, Mineral Waxes 28
Inorganic Chemicals, Precious Metals, Rare
earths, Radioactive elements 29 Organic
Chemicals 30 Pharmaceuticals 31 Fertilisers 32
Tanning and Dying, Pigments and Colourings,
Paints, Varnishes 34 Soap and Lubricants 35
Albumin, Starches, Glues and Enzymes 38
Miscellaneous Chemicals (pesticides, waste) 39
Plastics (polymers)
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How do we classify? The majority of substances
are classified according to their chemical
structure Extract from the beginning of Chapter
29, 2902 Cyclic Hydrocarbons
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• Not all substances are classified by structure
• All radioactive substances are in the section
  with inorganic chemicals
• Some substances are classified by their source,
  such as vegetable alkaloids
• Some substances are classified by their source
  and destination, such as antibiotics
• Some substances whether natural or synthetic are
  classified by their use, such as hormones
• Substances used as colourings and pigments are
  classified by the dye process, such as acid,
  mordant, direct, vat
• There will be a new heading for mercury compounds
  in 2007 in chapter 28 which will include all
  mercury substances, whether they are inorganic or
  not

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Substance definition Chapter 29 organic chemicals

• Note 1 except where the context otherwise
  requires, the headings of this chapter apply only
  to
• Separate chemically defined compounds, whether or
  not containing impurities
• Mixtures of two or more isomers of the same
  organic compound (whether or not containing
  impurities, except
• The products mentioned in (a), (b), (c) above
  dissolved in water
• The products mentioned in (a), (b), (c) above
  dissolved in other solvents provided that
• The products mentioned in (a), (b), (c), (d), (e)
  above with an added stabilizer necessary for
  their preservation or transport
• The products mentioned in (a), (b), (c), (d),
  (e), (f) with an added anti-dusting agent or a
  coloring or odoriferous substance added to
  facilitate the identification

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The Importance of names for Chemical
Identification Variety of standard names of
substances which are well known, and well
documented, ISO, INN, Colour Index Variety of
trivial names which are generally recognised and
universally accepted and form part of the IUPAC
rules Variety of IUPAC, CAS and other systematic
names which enable classification of substances
by using computer generated structures Eg.
2-chloro-1,1-dimethoxyethane CAS 97-97-2
CN classification, on ECICS database 2911 00 00
Justification Hemi acetal, halogenated
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Other Aids for Classification for ECICS Database
Substance Is it a new entry? Compare with
existing ECICS names and CAS numbers Is it
similar to an existing entry? Search for salts,
esters, isomers use existing ECICS
classification and control in White Book WCO on
line database (for the first 6 figures) check
if listed or if similar substance is listed, then
add last 2 figures from White Book Harmonised
System (HS) scientific sub committee classify
many pharmaceutical products (for the first 6
figures) add the last 2 figures from the White
Book Internet search for structural diagram
from reliable sources such as PubChem, WHO, or
other chemical databases. Examine possible uses
of substance eg Dyes, or sources eg Antibiotics,
classify from scratch using the white book
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For ECICS upgrade, new traded substances will be
added to the ECICS database In order to classify
these substances, an accurate structure must be
generated using the name of the substance eg
ELINCS 430-810-3, CAS 154825-62-4 2-4-(4-methoxyp
henyl)-6-phenyl-1,3,5-triazin-2-yl-phenol, from
Annex 1 on the Classification and Labelling
database
Classification under the CN system Heterocycle
with Nitrogen atoms only, containing unfused
triazine ring, other, other, result 2933 69
80 IUPAC name generated by ACD software 2-4-(4-me
thoxyphenyl)-6-phenyl-1,3,5-triazin-2-ylphenol
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Whats in a name? That which we call a rose by
any other name would smell as sweet! (William
Shakespeare, Romeo and Juliet)The problems of
identification of substances by name
ELINCS 430-810-3, CAS 154825-62-4 2-4-(4-methoxyp
henyl)-6-phenyl-1,3,5-triazin-2-ylphenol 2-4-(4-
methoxyphenyl)-6-phenyl-1,3,5-triazin-2-yl-phenol
Fragrance AH from RIP 3.10 constituent A, p.51
CAS 127-51-5 3-methyl-4-(2,6,6-trimethyl-2-cyclohe
xen-1-yl)but-3-en-2-one 3-methyl-4-(2,6,6-trimeth
yl-2-cyclohexen-1-yl)-3-buten-2-one
If any other character from either name has been
missed out or inserted in these names, the names
would not have run on the structure generating
software. All the names produce structures with
no error messages, but the computer cannot
recognise these substances as being the same
substances because they are not identical names
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The Use of IUPAC names
Fragrance AH, constituent A, CAS no 127-51-5
IUPAC name 3-methyl-4-(2,6,6-trimethyl-2-cyclohe
xen-1-yl)-but-3-en-2-one (Source EINECS)
(Z)-3-methyl-4-(2,6,6-trimethyl-1-cyclohex-2-enyl)
but-3-en-2-one ? (Source NIST) (3E)-3-methyl-4-(2
,6,6-trimethylcyclohex-2-en-1-yl)but-3-en-2-one ?
(Source ACD) For the ECICS customs classification
this information is not relevant for this
substance, however to improve and upgrade the
database it is useful to know whether the name
intends both isomers, and what the CAS number
really applies to
E Isomer
Z Isomer
Either Isomer
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Other Systematic Names Fragrance AH constituent
C, Cas Number 127-42-4 EINECS 204-842-1 1-(2,6,6-
Trimethyl-2-cyclohexen-1-yl)-1-penten-3-one 5-(2,6
,6-Trimethyl-2-cyclohexen-1-yl)-4-penten-3-one (2
structures available) 5-(2,6,6-Trimethyl-2-cycloh
exenyl)-4-penten-3-one Cetone, alpha-
(unrecognisable) Methylionone, alpha
(unrecognisable) (R-(E))-1-(2,6,6-Trimethyl-2-cycl
ohexen-1-yl)pent-1-en-3-one (syntax error, but
name listed on RIP 3.10 as EC name) 1-Penten-3-one
, 1-((1R)-2,6,6-trimethyl-2-cyclohexen-1-yl)-,
(1E)- (name listed on RIP 3.10 as CAS name)
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Other representations of substances - Structural
Drawings
1-(2,6,6-trimethylcyclohex-2-en-1-yl)pent-1-en-3-o
ne IUPAC name submitted RIP 3.10 (1E)-1-(2,6,6-
trimethylcyclohex-2-en-1-yl)pent-1-en-3-one Name
applicable to the drawing submitted And finally
structure we believe they REALLY mean from the
CAS name they have supplied in RIP
3.10 (1E)-1-(1R)-2,6,6-trimethylcyclohex-2-en-1-y
lpent-1-en-3-one
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Comparison of Molecular structures using
alternative methods - SMILES notations Fragrance
AH RIP 3.10 constituent C SMILES notation
supplied is OC(CCC(C(CCC1)C)C1(C)C)CC Alternati
ve quoted from PubChem is CCC(O)CCC1C(CCCC1(C)C
)C Alternative generated by ACD is
CC1CCCC(C)(C)C1CCC(O)CC Using the Online
SMILES translator for unique SMILES CCC(O)CCC1C(
CCCC1(C)C)C Alternative generated by ACD
including the R bond C\C1C\CCC(C)(C)C_at_H1/CC/C(
O)CC The presence of many options for SMILES
code configuration makes SMILES codes difficult
to use for detection of duplicates within the
database
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Constituent C represented as InChi InChI1/C14H22O
/c1-5-12(15)8-9-13-11(2)7-6-10-14(13,3)4/h7-9,13H,
5-6,10H2,1-4H3/b9-8 (E Isomer) InChI1/C14H22O/c1
-5-12(15)8-9-13-11(2)7-6-10-14(13,3)4/h7-9,13H,5-6
,10H2,1-4H3/b9-8- (Z Isomer) InChI1/C14H22O/c1-5
-12(15)8-9-13-11(2)7-6-10-14(13,3)4/h7-9,13H,5-6,1
0H2,1-4H3 (quoted by PubChem with unspecified
double bond) The consistency of the text strings
within the InChi make this code system a more
useful tool for structure comparison within
ECICS Other options on InChi would
be- InChI1/C14H22O/c1-5-12(15)8-9-13-11(2)7-6-10
-14(13,3)4/h7-9,13H,5-6,10H2,1-4H3/b9-8u
(undefined bond) InChI1/C14H22O/c1-5-12(15)8-9-13
-11(2)7-6-10-14(13,3)4/h7-9,13H,5-6,10H2,1-4H3/b9-
8? (unknown bond) InChI1/C14H22O/c1-5-12(15)8-9-
13-11(2)7-6-10-14(13,3)4/h7-9,13H,5-6,10H2,1-4H3/b
9-8/t13-/m1/s1 (E Isomer with R bond)
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• The documentation supplied for constituent C is
  an illustration of typical problems we face
  everyday, trying to work out whether we are
  considering is an existing ECICS substance or a
  new substance for introduction to the database,
  and what is really intended by the name supplied.
• Having agreed on a structure we must agree on a
  correct classification
• Not all substances are easily identifiable
• WCO have discussed some pharmaceuticals for over
  10 years and have still not agreed
• Some substances vary in composition, others
  simply not known
• Technological advancement is faster than the
  updates in the HS system so more legal
  definitions are needed imunomodulator or
  modifier?
• Chemistry or Biology?

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Amusement- Using the Technical Guidance from RIP
3.10, how many different SMILES notations can you
generate for pyridine?
Answer 12, then the computer can develop 3
more! How many InChi codes can you develop?
Answer 1
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Policy Support I TAXUD, TRADE regulation EC
2658/87

• WTO Free Trade Agreement on Pharmaceuticals, 3rd
  Update
• Subject
• WHO-INN Lists 79-93 annex 3
• Lists of Prefixes and suffixes, which in
  combination of annex 3 describes salts, esters
  and hydrates annex 4 complete revision
  according to WHO, IUPAC
• Lists of pharmaceutical intermediates annex 6
  data consolidation by providing substance
  identification and substance customs
  classification data
• Procedures
• Technical working group meetings at WTO 2
• Technical meetings for data evaluation 2 TAXUD,
  MS, WHO, WCO

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Policy Support II TAXUD, ENVEC 304/2003

• Data compiled
• Names 304/2003, EINECS, ECICS, ISO, IUPAC
• ID CAS, EINECS, CUS
• Graphical representation
• Customs Classification CN, HS_2007
• Recommendations to DG ENV
• Rename compounds 7
• Correction of CAS 2, EINECS 8
• Addition of CAS 3, EINECS 8
• Correction of CN 10, Addition of CN
• Recommendations to group entries
• Review TAXUD, MS, ENV in 5/2006

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Policy Support III TAXUD, ENV?67/548 EEC

• Data compilation
• Names IUPAC, ISO, INN, INCI, C.I., names found
  in legislation
• Graphical representation, if not UVCB molecular
  formula
• ID CAS, EINECS
• Comments to the naming of substances gt 200 well
  defined substances or mixtures of well defined
  substances without proper naming
• Substance customs classification

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Contributions to the ECICS Redesign the database

• Development of the new software with different
  levels of users - data - confidentiality (from
  laboratories to public)
• New features
• new translation module
• searchable developed structures
• new fields new identifiers, typical purities,
  chemical and physical properties, spectra,
  chromatograms, risk warnings, danger warnings,
  MSDS, extracts of CAS database and other sources
• linked to other applications
• customs clearance (automatic filling)
• risk analysis
• central access point for all information
  concerning the movement of the chemicals
  (legislations in force, other concerned
  administrations)
• Studies 2005-2006, 1st phase of development
  2006-2007

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Contribution to the ECICS Future Database upgrades

• Revision, correction and enrichment of current
  data
• IUPAC name
• Structure InChI
• International name standards
• Addition of new products (including mixtures and
  preparations) gt 200 000
• ECICS lt 30.000 substances
• CHEMLIST more than 100 inventories and
  regulatory list containing more than 237.000
  substances
• CHEMCATS A list of more than 8 million
  substances commercially available substances
• CAS more 25 million substances registered
• PubChem more than 5 million substances ID data
  and more public available
• limiting factor classification