Is UFI Alone Enough?
For several years now, many chemical product labels have featured a UFI (Unique Formula Identifier) code. For many companies, it has become a symbol of compliance with the notification obligations for hazardous mixtures. But does simply placing the UFI on the label really mean that a company has fulfilled all legal requirements? What should you ask your supplier?
In this article, we clarify a common misconception: the UFI is only one element of the mandatory Poison Centre Notification (PCN).
What is UFI?
UFI (Unique Formula Identifier) is a 16-character alphanumeric code that uniquely identifies a mixture. This code is linked to information submitted to authorities responsible for providing emergency health responses, such as poison centres.
Placing the UFI on the product label is mandatory, but on its own, it does not convey any information about the composition of the mixture. For the code to be meaningful, it must be linked to a PCN submission.
What does the PCN obligation include?
Submitting a Poison Centre Notification (PCN) means providing detailed information to the relevant authority, including:
- identification of the mixture (including the UFI),
- information about the product's composition,
- toxicological data,
- CLP classification,
- intended use and product category,
- labelling elements.
📌 What does this mean in practice?
If a product label only displays a UFI code but no notification has been submitted, or if the submission is incomplete, the company is not compliant with legal requirements. Such a UFI is essentially “empty” — it is not backed by a valid PCN submission.
Common PCN notification mistakes by companies
- Placing a UFI without submitting a PCN – e.g. generating a UFI in the ECHA tool but not completing the notification process.
- Failing to verify in which countries the PCN has been submitted – not all suppliers submit PCNs for all markets. It is important to check this during supplier discussions. If the supplier has not submitted a PCN in Poland, you may be responsible for doing so.
- Changing the composition without updating the PCN and UFI – any change affecting the composition requires a new UFI and an updated notification.
Can a UFI ever be used without a PCN submission?
No. The UFI is just a “key” — the underlying data must be submitted. An unlinked or “empty” UFI can be misleading. Even if a product is exempt from notification, placing a UFI on the label triggers the obligation to submit a PCN. According to Annex VIII of the CLP Regulation, full notification is required for all hazardous mixtures placed on the EU market.
How to ensure your products are compliant with Annex VIII of CLP?
- Check whether your submissions have been accepted in the ECHA Submission Portal.
- Verify that the UFI on the label corresponds to the submitted mixture.
- Remember to update the notification in case of changes in composition or classification.
- Keep documentation confirming the PCN submission — it may be required during inspections.
- When talking to suppliers, make sure they have not only provided the UFI but have also submitted the PCN, and check in which countries the mixture has been notified.
📌 Good to know:
In some cases (e.g. toll manufacturing, repackaging), the obligation to notify may rest with different actors — it is essential to clearly define roles and responsibilities in the supply chain.
Summary
Having a UFI on the label is not enough. The code must be linked to a complete submission to the relevant authorities. Companies that only generate the UFI without submitting a PCN are not compliant with legal requirements.
Need support with PCN submissions?
Contact us — we’ll help you verify whether your notifications are complete and compliant with the latest regulations.
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