If your company sells hazardous chemical mixtures in the EU, there’s a crucial deadline on the horizon that you can’t afford to ignore - end of UFI code transition period. By January 2025, the European Chemicals Agency (ECHA) will launch a six-month inspection campaign to ensure UFI code compliance with Poison Centre Notification (PCN) regulations. To prepare, businesses must focus on the correct submission of product information and proper use of the Unique Formula Identifier (UFI) code. This inspection could have significant consequences for companies that are not fully compliant.
Why January 2025 Matters for UFI Code Requirements
As of 2024, companies are required to submit information about hazardous mixtures using a standardized format established by the EU. This isn’t a one-time task; any change to your product’s formula or identifier will require a new/updated PCN submission, and the upcoming inspections will focus on whether these updates have been properly made. ECHA will closely examine labels, Safety Data Sheets (SDS), and especially the use of the UFI code—a 16-character alphanumeric code designed to link a specific mixture to the exact data submitted to poison centers.
The UFI code is essential for emergency health response, allowing poison centers to identify the composition of hazardous mixtures rapidly. If your product lacks a UFI or has incorrect labeling or an outdated SDS, your business may face penalties, or worse, lose the right to sell within the EU. The January 2025 inspection marks the end of the transition period for UFI compliance, leaving no room for error.
What is the UFI Code and Why is It Critical?
The UFI code is a key requirement under the CLP Regulation (EC No. 1272/2008), specifically aimed at ensuring accurate identification of hazardous mixtures in case of emergencies. It must be placed on the product label, alongside the product’s name and details. The information tied to this UFI code is submitted to poison centers via PCN. This helps first responders quickly identify the ingredients in hazardous chemical products, reducing the risk of delays in treatment during emergencies.
Who Needs to Comply with UFI Code requirements?
If you are an importer or formulator of hazardous chemical mixtures within the EU/EEA, or if you sell mixtures imported from outside the EU, you are considered a duty holder under Annex VIII of the CLP Regulation. Even if you are merely importing products for internal use, without selling them, you still need to submit a PCN for the Member State where you operate.
For companies outside the EU/EEA, compliance involves appointing an EU-based representative to manage PCN submissions. The UFI code helps protect your product’s confidential formula by associating it with the correct mixture data without revealing proprietary information.
How to Ensure UFI Code Compliance Before the Deadline
Review Your Product Portfolio: Identify which of your products require a UFI code and PCN submission. Double-check if you need to resubmit data due to changes in product formulation.
Check Member State Requirements: If your product is sold in multiple Member States, ensure that each one has been properly notified through the ECHA submission portal. If a customer plans to sell in a new country, ensure you submit updates as needed to cover the additional market.
Verify Labels and SDS: Make sure your product labels display the UFI code clearly, and that your Safety Data Sheets are up to date and accurate.
UFI Code Fee: We would like to point out that certain countries also have additional fees for PC notifications. We have already written more about this in our blog titled UFI code and PC notification price
Consult Experts: If you're unsure of your compliance status, consider working with a regulatory expert to help manage your PCN submissions and UFI labeling before the January 2025 deadline. You can contact us to info@chem-consulting.si
The UFI Code Inspections Are Coming: Will You Be Ready?
The upcoming inspections will focus heavily on labelling, classification, and packaging of hazardous chemical products. From 2026, the EU’s REF-14 project will increase the scrutiny of product safety to ensure proper labeling and packaging that protects consumers, including the mandatory use of child-resistant fasteners.
Products like air fresheners and e-cigarettes are already under the microscope due to frequent mislabelling and inadequate warnings about potential hazards. Without proper classification and UFI codes, your products could pose significant risks to consumers, and the ECHA’s 2025 inspection campaign will be the first step in clamping down on non-compliance.
Don’t Risk Your Business—Act Now
Missing the January 2025 deadline for PCN submissions and UFI labelling could have severe repercussions. The final phase of the UFI compliance process is underway, and time is running out. If you need help navigating the regulatory maze, now is the time to act. Reach out to regulatory consultants like us (info@chem-consulting.si) to ensure that your products remain on the market and meet all EU safety requirements.
Stay ahead of the curve, and make sure your products are ready for the ECHA's upcoming inspections.
Comments