The license plate of a car is a way to recognize a car, to find your car, to arrange insurance and taxes. When mentioning the license plate every authority immediately knows which car is meant. Provided you drive too fast or if the traffic light turns really dark orange when you just drive past. Or worse, if you don’t have a license plate on your car, then everyone immediately knows there’s more to it…
The UFI is similar! The “license plate” of your classified product. If there is no UFI on your classified product,everyone knows that something is not right. When you do have it mentioned, inspecting authorities can quickly see whether you have actually completed the registration at the poison control centre.
Mentioning the UFI (Unique Formula Identifier) on a product is a relatively simple part of the new Poison Centre Notification (PCN-Portal). The only task of the UFI in this whole process is to be able to identify the product or rather a formulation. But this relatively simple UFI does pose a number of challenges for the producer / seller / supplier of hazardous mixtures in a number of areas:
Administration: Keeping track of UFI’s, formulation numbers and registration number of your formulations and products is quite a challenge, especially if products get multiple formulations over time. Also you need to keep this information of your resources to know when a UFI or the registration needs to be renewed.
Private label: One private label wants you to use his UFI and the other wants you to create a unique UFI for him. This not only requires an extremely accurate administration, but it also revolves around good communication. Who decides when a new UFI is needed? Who applies for the UFI? Who takes care of the registration?
Imports: Producers or suppliers from outside the EU are likely to be unfamiliar with the new legislation and will find it difficult to comply. Applying for a UFI alone is difficult because you need a European VAT number.
Hiding is no longer an option: no UFI on the label means not complying with laws and regulations!
The UFI seems simple but requires a lot of administrative actions. Processes must be set up, systems must be adapted to keep track of the correct information and labels must be made with the correct UFI’s. Compared to REACH, this change applies to many more companies, especially SMEs. So many companies will have to deal with it and make changes to processes and labeling.
Hiding is not an option, the “police” will quickly catch you if you sell without a “license plate”.