Quick Understanding of EU CLP-PCN-UFI Registration Process
Date：2026-02-05 09:16:44 Classification
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CLP, PCN, and UFI are three closely related yet distinct concepts that collectively constitute the EU's comprehensive management system for the classification, labeling, packaging, and emergency notification of hazardous chemical mixtures (i.e., preparations such as cleaning agents, paints, glues, etc.).
Quick understanding of core concepts
1. CLP: The regulation itself. Its full name is the "Classification, Labelling and Packaging Regulation for Chemicals". It stipulates how to classify chemicals based on their physical, health, and environmental hazards, and specifies corresponding label elements (pictograms, signal words, hazard statements, etc.) and packaging standards. This serves as the legal and technical foundation for all work.
2. UFI: Unique Formula Identifier. It is a unique code consisting of 16 alphanumeric characters, formatted as XXXX-XXXX-XXXX-XXXX (e.g., A1B2-C3D4-E5F6-7890). It must be printed on labels that comply with CLP requirements.
3. PCN: Submission portal and process. Its full name is "Poison Center Notification". It specifically refers to the entire process where enterprises submit product information (especially formulation information containing UFI) to designated agencies in various countries through the EU's unified PCN portal in a specific PCN format.
Step 1: Perform CLP hazard classification (technical core)
Method: Evaluate all components of the product in accordance with the Annex of the EU CLP Regulation (EC) No 1272/2008.
Required data: complete formula of the product (CAS numbers and accurate concentration ranges of all ingredients), physicochemical properties and toxicological data of each ingredient (usually sourced from SDS or databases of pure substances).
Result: Determine which hazard categories the product belongs to (such as flammable liquid category 2, acute toxicity category 4, skin corrosion category 1B, etc.), and derive the corresponding pictograms, signal words, hazard statements (H phrases), and precautionary statements (P phrases).
Who will do it: It is usually done by the internal regulatory specialist of the enterprise or by entrusting a professional third-party consulting/testing agency. This is the most professional part of the entire process.
Step 2: Generate UFI
Method: Create for free on the official "UFI Generator" webpage of the European Union.
Input information: The VAT number or EU company registration number of the submitter (usually the responsible entity within the EU, such as the importer or the sole representative) is required.
Key point: One product formula corresponds to one UFI. If there are substantial changes to the formula (such as concentration changes that affect classification), a new UFI needs to be generated.
Step 3: Create/update product labels
Method: Print all label elements (pictograms, signal words, H/P statements) generated by CLP classification, as well as the generated UFI, on the product packaging in accordance with the format and size required by regulations.
The annotation format for UFI: it must be annotated as UFI: XXXX-XXXX-XXXX-XXXX.
Step 4: Submit a notification through the PCN portal (core administrative step)
This is the step of formally submitting the information to the Poison Centers of EU member states.
Platform: Utilize the EU's PCN portal.
Submitter: Must be a responsible entity (legal entity, such as manufacturer, importer, or authorized representative) within the EU. Non-EU enterprises must designate an "authorized representative" to fulfill this obligation.
Submission format: Use the internationally unified "PCN format". This requires filling in product information, UFI, classification, formula, toxicological information, etc., according to a complex XML schema. Typically, professional business software or third-party service providers are needed to complete data preparation and submission.
Submission language: The "Product Use Category" and "Intended Use" sections of the notification must be in the official language of the country where the product is launched. Other sections (such as ingredient information) are typically in English.
Time: The notification must be completed before the product is first placed on the EU market. For consumer products, the regulation provides a transition period, but the notification for all existing dangerous mixtures must be completed by January 1, 2025 at the latest.
Final advice: Given the highly specialized nature of the CLP/PCN/UFI processes and the legal responsibilities involved, for most enterprises (especially small and medium-sized enterprises handling it for the first time), the safest and most efficient approach is to entrust experienced third-party compliance service providers or consulting firms to assist in the entire process. They can ensure the correctness of the procedures and compliance of data, while reducing your legal risks.
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