The new “Poison Centre Notification (PCN)” is going to drastically change the way we notify hazardous mixtures at the poison centres. The procedure is set out in the new ANNEX VIII of CLP, and in the meantime there is also a provisional Guidance available via this link. Although the full procedure is not fully official yet and the legislation is not yet in effect, we can already look at how the procedures are most likely going to be and how much effort it takes to comply with the new procedure. In the coming year I will describe several different parts of the PCN. In this BLOG we will start with the UFI.
What is the UFI?
The “unique formula identifier” (UFI) is an alphanumeric code of 16 characters long.
Example UFI: H563-L90S-R783-J823
The UFI will be used to define compositions of hazardous mixtures. The UFI is required to be stated on the label of hazardous mixtures, in order to be immediately identified in the event of an accident. This makes the UFI the start of the registration to the new PCN-portal.
How to generate a UFI?
You can create a UFI through ECHA’s online UFI generator. For this you will need the following:
- VAT number (or a company key when there is no VAT number available).
- Formulation numbers (a number between 0 – 268 435 255, that you assign yourself to a formulation).
The UFI generator is online available via https://ufi.echa.europa.eu/#/create, you can also verify a UFI or request a company key here. NOTE: De UFI generator does not warn for double UFIs. You will have to keep track of whether you have already created a UFI or not.
When do you create a UFI?
You have to create a UFI if you place a mixture in the market that is classified for physical or health hazards. Every time the composition of the mixture changes, beyond the allowed differences, you will have to make a new UFI and update the Poison Centre Notification (PCN). For example, when an ingredient is added, changed or removed. The new UFI has to be used on all labels from that moment onwards.
From when is the UFI mandatory?
The UFI is mandatory for consumer mixtures from 1 January 2020; for mixtures for professional use from 1 January 2021 and for industrial use from 1 January 2024. Mixtures that are already placed on the market and registered via the current procedure have a transition period until 1 January 2025.
Why already think about the UFI now?
The PCN will cause quite the change, even the relatively simple UFI already has several significant effects for the seller or supplier of hazardous mixtures.
Let’s start with the seemingly simple task of creating a UFI, for this you need 2 numbers:
- VAT number (when this isn’t available ECHA has a method to create a company key).
- Formulation number (a number between 0 and 268 435 255).
The first one is usually no problem and there is a solution if there is no VAT number available. The second seems like a simple number, but if we think about this for a moment… turns out that we have to maintain and update 2 new numbers in our internal systems, namely the UFI itself but also the formulation number. Each time the composition changes, beyond the allowed differences, both numbers have to be changed. When it comes to 3 products that is reasonable, but when it comes to 10 products it becomes more difficult. A single product name can have multiple UFIs and formulation numbers over time, all of which have to be tracked.
There is no hiding anymore: no UFI on the labels means not complying with laws and regulations!
Administratively not an easy one, especially if you also have to keep track of in which country the UFI is registered or not. Not to mention creating UFIs for the same formulations that you don’t want to use the same UFI in the market for, or creating UFIs for products from suppliers that you don’t change but also don’t want to use the same UFI as your supplier does on the label.
The UFI seems simple but requires a lot of administrative actions, processes have to be set up, systems have to be adjusted to keep track of the correct information and labels have to be adjusted with the correct UFIs. In comparison 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 labelling. And there is no hiding, no UFI on the label means not registered and therefore not complying with legislation! It’s also very noticeable if there is no UFI on the label.
So prepare well and start on time!