Everything You Need to Know About Voluntary UFI Codes

If you're involved in manufacturing or importing hazardous chemical mixtures into the European Union (EU), you're likely aware of the Poison Centre Notification (PCN) requirements and voluntary UFI codes. Since 2021, the Classification, Labelling, and Packaging (CLP) Regulation mandates that such mixtures be notified to Poison Centres in each EU member state where they are placed on the market. This notification includes a Unique Formula Identifier (UFI), a 16-character alphanumeric code that links a product to its specific formulation.

However, for non-EU manufacturers or those seeking to protect proprietary formulations, submitting a voluntary PCN can be a strategic move. This blog post delves into what voluntary UFI codes are, how to submit them, and how they can simplify your compliance strategy.

What are Voluntary UFI Codes?

A voluntary UFI code is an alphanumeric identifier generated through a voluntary Poison Centre Notification (PCN). Unlike mandatory PCNs, which are required by law, voluntary PCNs are submitted by companies that are not legally obligated to do so but choose to facilitate compliance for their customers. This is particularly beneficial for non-EU manufacturers who wish to support their EU-based importers or distributors.

When Should You Use a Voluntary UFI Code?

Consider submitting a voluntary UFI code if:

• You're a Non-EU Manufacturer: You cannot submit a mandatory PCN because you're not an EU entity, but a voluntary PCN allows you to support your customers.

• You Want to Protect Your Formula: Instead of disclosing full composition details to each importer, you can submit a voluntary PCN and provide them with the UFI they need to fulfil the composition requirements when submitting their own PCNs.

• Your Importers Need Compliance Assistance: Many importers lack the resources or expertise to handle PCN submissions. Providing them with a voluntary UFI can simplify their process.

How to Submit Voluntary UFI Codes

If you're considering submitting a voluntary UFI code, there are several important steps you’ll need to follow to ensure everything is handled correctly.

1. Collect the Required Information: Start by compiling all the essential details about your product. This includes the full chemical formulation, toxicology data to evaluate health and safety risks, labelling and classification details according to the CLP regulation, product names, packaging descriptions, and intended usage—whether it’s for consumers, professionals, or industrial purposes.

2. Appoint a Representative Within the EU/EEA or Northern Ireland: Because non-EU companies can’t directly submit a PCN, you’ll need a legal entity located in the EU, EEA, or Northern Ireland to act on your behalf. This entity will also be responsible for generating the UFI code associated with your product.

3. Prepare the Notification Dossier: With the UFI created, the next step is to put together a notification dossier. This can be done through ECHA’s Submission Portal or a compliance software tool. The dossier must include the UFI, product details, the markets it will be sold in, and the information of the legal entity submitting the PCN.

4. Send the Submission: Submit the completed dossier via the ECHA Submission Portal. Once accepted, a confirmation will be issued, and the information becomes available to the appropriate Poison Centres.

5. Notify Your Partners: Even though a voluntary PCN can streamline the process, it doesn’t take over the legal responsibilities of importers. You must share the UFI and relevant submission details with them so they can meet their own compliance duties.

6. Keep Information Up to Date: If anything changes—whether it's the formulation, your distribution partners, or the countries where the product is sold—you’ll need to revise your PCN. Staying current with both regulatory updates and your own product data is essential for continued compliance.

We offer a free contract to non-EU companies, as a basis for PCN notifications.

If you need help, we are the right address for you. You can reach us at info@chem-consulting.si for an informative quote.

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