ECHA organized a great webinar on the subject of UFI codes entitled: "Poison center notifications: ensuring compliance for industrial use mixtures".
During the meeting, the attendees also asked some very good questions about UFI codes, which we highlight below:
"How can an outside-EU supplier submit the PCN / UFI code in ECHA-Portal?"
ECHA reply:
"The CLP Regulation, from which the PCN duties come from, applies only to EU based companies. Therefore, non-EU suppliers cannot submit PCN directly.
Your customers, which are the importers based in the EU, are the ones responsible to comply with this duty.
If for the sake of confidentiality, you do not want to share the full composition of your mixture, and are also not willing to provide a REACH-compliant SDS, then you can use a workaround. In brief, you need to agree with another EUbased company which you trust, to submit a voluntary PCN with the full composition.
Then your customer can refer to it as a 100% MiM, one you provide him with the UFI. It is further explained in the Guidance on Annex VIII, Section 4.2.5 "UFI and non-EU suppliers".
We already wrote a BLOG on this topic, where you can find information that we offer a free contract to non-EU companies, as a basis for PCN notifications. Contact us for more information (info@chem-consulting.si).
"How ECHA secure my data in the portal in order to guarantee confidentiality of information?"
ECHA reply:
"Security is one of the most important aspects of the system. The ECHA IT system for PCN notifications is designed in a way that the information is made available only to the entities that are supposed to receive it.
When an industry user has access to ECHA Submission portal, their connection is encrypted by using the standard TLS (Transport Layer Security) protocol. Thus, all the data is encrypted with the commonly used strong encryption algorithms when transmitted through the established communication channel over Internet between Industry user’s system (client) and ECHA Submission portal (server).
Poison Centres notification data submitted by industry is not encrypted when stored in the ECHA ITsystem (data as rest). ECHA IT-environment, and the data stored in the systems, is protected by applying other security measures and controls than encryption. The protection in place is based on common security best practices."
"May a non-EU supplier use it's own subsidiary EU company to make just a voluntarily submission for the UFI (to be given to its EU customers) without an obligation to become an importer/duty holder?"
ECHA reply:
"A non-EU supplier will never be a duty holder nor an importer under EU Regulations. Their actions are voluntary and meant to support the EU customers."
You can check more questions HERE.
Watch the recording:
SOURCE: ECHA
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