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We produce a hazardous mixture in the EU, but only sell it to non-EU countries. Do we need UFI code?

Hazardous mixtures which are formulated only for export and are not placed on the EU market do not need UFI code and consequently they also don't need PC notification.


More information is available in Guidance on harmonised information relating to emergency health response – Annex VIII to CLP, section 3.1.1.2., where it is stated:


"A company that formulates a mixture exclusively for export, and does not place it on the EU market, does not have the obligation to make the submission."


However, it is also necessary to pay attention to storage, as it is written later in the chapter:


"If the product is stored in a temporary warehouse before being exported outside the EU, this may qualify as placing on the market and therefore the obligations according to Annex VIII apply.


This would be the case if, for example, the formulator makes available the mixture, whether in return for payment or free of charge, to a third party which stores the mixture in the warehouse before delivering it to a non-EU company.


If the mixtures are stored in a warehouse by the same downstream user that formulates them, there are no obligations to submit information.


As long as there is no placing on the market (i.e. making the mixture available to a third party), the warehouse that belongs to the downstream user can be located in a different place from where the formulation takes place (the same or a different Member State)."


UFI code for export

SOURCE: Guidance on harmonised information relating to emergency health response – Annex VIII to CLP, ECHA


If you need to arrange UFI codes, contact us, as we have a very affordable package offer with an included safety data sheet. We are available at info@chem-consulting.si.


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