From 1 January 2024, all newly submitted poison center notifications must comply with the harmonized information requirements outlined in Annex VIII of the CLP Regulation. This also includes a UFI code on the label. Therefore, importers and downstream users of industrial use only mixtures need to be aware of the upcoming second poison center compliance date.

PCN Transition period:

• Mixture for professional and consumer use: effective from 1 January 2021.
• Mixtures for industrial use: effective from 1 January 2024.

What is UFI?

Unique Formula Identifier, known as UFI, is a string of 16 alphanumeric characters. For example, YV9K-3J9A-G209-xxxx. UFI is like the "ID number" of the mixture product and it can link to the exact notification information of a mixture. Therefore, only UFIs that have completed the Poison Centres Notification (PCN) are valid and can be used for health emergency response.

How to use UFI?

Non-EU companies often need to inform their importers about their mixture components to fulfill their notification obligations under the CLP Regulation. However, the commercial disclosure of mixture formulation may arise at the same time. Non-EU companies can maintain the confidentiality of their formulations by designating a legal entity in the EU to submit a voluntary notification. It is then possible to obtain a valid UFI (Unique Formula Identifier) for the mixture product. In this way, it is only necessary for these companies to provide the importer with this notified UFI via SDS (Safety Data Sheet) or other means, without disclosing specific formulation information.

ChemRadar Insights:

Companies that have completed their notifications under requirements are applicable to the transition period, which means the original notification will remain valid until 1 January 2025. However, if there are any changes to the product during this period, such as changes to the mixture composition, toxicological property, or UFI, the notification must be resubmitted in a harmonized format through the ECHA (European Chemicals Agency).

Companies applicable to the transition period are advised to update their notification time and change the UFI code on the label.

What should enterprises do?

Chinese enterprises involved in the production or handling of hazardous chemicals should pay attention to the UFI changes. Firstly, companies need to assess their products meet and confirm their Unique Formula Identifier (UFI) on the labels. As we all know, the UFI was introduced to improve the efficiency of product identification in emergency health response, supporting rapid and accurate hazard assessment.

During the transition period, enterprises should update their notified information to ensure compliance with CLP Annex VIII. If the composition or intended use of a product changes, they should immediately update relevant information for product compliance.