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UFI code and non-EU supplier

Are you a manufacturer of hazardous chemicals based outside the EU and want to carry out PCN notifications and obtain UFI codes? Can you meet the requirements on behalf of a non-EU company?

The answer is NO. To meet the PCN requirements you need an EU-based business partner/distributor.

Duty holders under Article 45 are defined as importers and downstream users placing hazardous mixtures on the market. In all cases, the obligation lies with the EU legal entity, which means that a non-EU supplier of the mixture cannot replace the EU-based duty holder.

It is also important to consider that fulfilment of the notification obligation is a precondition for placing the mixture on the market – this may be important in cases where placing on the market is not performed by the importer or downstream user.

For which mixtures do you need to prepare PCN notification?

The obligation applies to mixtures placed on the market that are classified for human health or physical hazards.

Note that biocidal products and plant protection products are within the scope of this obligation, and the information submission requirements apply in addition to other obligations under the Biocidal Products Regulation and Plant Protection Products Regulation.

If you need help with PCN notifications and UFI codes, our team is here for you. Contact us at


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