How to apply for EU CLP-PCN-UFI
Date：2025-02-06 10:31:52 Classification
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The EU CLP-PCN-UFI (Unique Formula Identifier) application process is designed to ensure the safe use and compliance management of chemicals in the EU market. The following are the key steps and precautions sorted out from multiple sources:
I. Overview of the application process
1. Confirm the scope of product application
The product range that needs to generate UFI is mainly dangerous substances and mixtures subject to CLP Regulation ((EC) No 1272/2008), including mixtures for consumer use, professional use and industrial use. From 2023, industrial mixtures are also included in the mandatory requirements.
2. Prepare declaration information
The following three types of information need to be collected:
- Submitter information: company name, address, contact information, EU value-added tax number (VAT), etc.;
- Product information: country of release, use (direct use and downstream user end use), packaging type and size;
- Mixture information: ingredient name, concentration, physicochemical properties (such as pH value, color), toxicological data, classification label, etc.
3. Generate UFI code
UFI is a 16-digit alphanumeric combination in the format of "UFI:XXXX-XXXX-XXXX-XXXX". There are two ways to generate it:
- EU companies: generate it using the VAT number;
- Non-EU companies: If you cannot provide VAT, you need to generate an internal number by entering a random number between 0-268435455.
*Note: Products with different formulas must be assigned different UFIs. Products with the same formula but different brands can flexibly choose the same or different UFIs. *
4. Adjust the Safety Data Sheet (SDS)
The information in the SDS must comply with ECHA's PCN notification requirements, such as marking UFI in Section 1.1, updating nanomaterials and endocrine disruptors, etc., to ensure that it passes the review.
5. Prepare and submit the notification dossier
Use the IUCLID format to prepare the dossier and submit it online through ECHA's Poison Center Notification Portal (PCN Portal). The dossier must include detailed information such as the ingredients of the mixture, hazard classification, and emergency measures.
6. Update maintenance and compliance obligations
If the product ingredients, use or packaging information changes, the notification content must be updated in a timely manner to ensure that the data is consistent with the market product.
7. UFI label display
The UFI must be clearly and indelibly marked on the label or packaging, and the location must be close to other label elements, without color or font size restrictions.
2. Special considerations for non-EU companies
- Entrust a third-party agency: Non-EU companies can make PCN notifications through a third party in the EU (such as deesev DTi) to protect commercial secrets. After the UFI is generated, it must still be submitted to ECHA.
- SDS compliance: From 2023, the SDS of products exported to Europe must comply with the new regulations (EU) 2020/878, otherwise they will not be able to enter the EU market.
3. Time period and professional support
- Processing period: Usually 4 working days, some agencies provide expedited services.
- Professional agency assistance: It is recommended to complete the application through a third-party agency with CNAS/CMA qualifications (such as deesev DTi), especially for companies with complex formulas or unfamiliar regulations.
IV. FAQs
- UFI’s role: In the event of an accident, UFI can be used to quickly obtain formula information and balance commercial confidentiality with public safety.
- The relationship between PCN and UFI: PCN is the process of submitting information to the poison center, and UFI is the unique identifier that links the product and notification data.
If you need more detailed regulatory interpretation or personalized guidance, you can contact a professional certification agency for support.
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