The European Union has introduced a significant UFI code related regulatory change impacting chemical distributors. Under the revised Classification, Labelling and Packaging (CLP) Regulation, distributors of hazardous chemical products must now report to poison centres. This marks a shift in responsibility that was previously only applicable to manufacturers and importers.
When Do These Obligations Take Effect?
The regulation states that these obligations will apply from 1 January 2027.
However, even under the current version of the CLP, distributors must ensure that their mixtures comply with CLP before placing them on the market. This requirement is explicitly stated in Article 4 (10): “Substances and mixtures shall not be placed on the market unless they comply with this Regulation.”
UFI code requirements: What Has Changed?
Before the revision, only manufacturers and importers were required to arrange UFI codes and submit Poison Centre Notifications (PCN) for hazardous mixtures. However, the recent amendment to the CLP Regulation extends this obligation to distributors. This means that distributors supplying hazardous chemicals under their own trade names must ensure compliance with notification requirements.
Why Is This Important?
Poison centres provide crucial information to medical professionals in cases of accidental exposure to hazardous chemicals. By requiring distributors to notify these centres, the EU aims to improve response times and accuracy in medical treatments, ultimately enhancing public safety.
Who Needs to Comply?
Distributors operating within the EU that place hazardous chemical products on the market under their own brand names must submit notifications to poison centres. If they simply resell products under the manufacturer’s original name and packaging, they may be exempt from this requirement. However, any relabeling, rebranding, or repackaging triggers the need for compliance.
What Must Be Reported?
Distributors must provide poison centres with:
The Unique Formula Identifier (UFI) for each hazardous mixture.
The chemical composition of the mixture.
Relevant toxicological information.
Product identification details and packaging specifications.
How to Stay Compliant
To ensure compliance, distributors should:
Assess Products – Determine which products require notifications.
Coordinate with Suppliers – Check if existing notifications cover their branded products.
Submit Notifications – Use the ECHA portal to submit accurate and complete data.
Keep Records Updated – Regularly update notifications as product compositions or packaging change.
Additional Considerations for Distributors
Distributors must submit a PCN if they place a product on a new marketplace where the notification has not yet been submitted or if they rebrand or relabel the mixtures. This includes assigning new trade names or Unique Formula Identifiers (UFIs) for all relevant marketplaces.
One alternative approach is to coordinate with suppliers to include the distributor’s trade names, UFIs, and relevant marketplaces in their PCN submission. It is crucial to obtain confirmation from the supplier that this has been done.
The key goal is to ensure that poison centres have full visibility of all relevant mixtures, including all trade names, UFIs, and the marketplaces where these products are sold.
This regulatory update underscores the EU’s commitment to safety and transparency in the chemical industry. Distributors must take swift action to meet their new obligations, ensuring they remain compliant while contributing to a safer market for hazardous chemical products.
For more details, visit the official ECHA Poison Centre website or consult us (info@chem-consulting.si) to navigate these new responsibilities effectively.
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