EU UFI registration process for epoxy resin
Date：2026-04-10 09:45:16 Classification
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EU UFI registration process for epoxy resin
1、 Overview of UFI Registration
UFI (Unique Formula Identifier) is a unique code assigned to mixture products containing hazardous ingredients in accordance with the EU CLP Regulation (EC) No 1272/2008 and the Toxic Substances Notification (PCN) requirements. Epoxy resin, as an important chemical mixture material, its products (such as epoxy resin adhesives, coatings, castables, flooring materials, etc.) must complete UFI registration when exported to the European Union.
Regulatory basis:
Article 45 and Annex I Part 5 of the EU CLP Regulation
ECHA guidance document: Guidance on the labeling and packaging of chemicals
Applicable time: Starting from January 1, 2021, all hazardous mixtures placed on the EU market must be notified and labeled with UFI.
2、 Prerequisite for Registration of Epoxy Resin UFI
1. Qualitative analysis of the product
Before registering with UFI, it is necessary to first clarify the classification attributes of epoxy resin products:
|Judgment element | Specific content
|Product type | Mixture (not a single substance)
|Hazard classification | Conduct hazard assessment according to CLP regulations
|Notification obligation | Whether classified as hazardous mixture
|Downstream use | industrial use, professional use, consumer use
Special note: Epoxy resin systems typically consist of two parts: epoxy resin prepolymers and curing agents, which may contain the following hazardous components:
Epoxy resin monomers (such as bisphenol A diglycidyl ether, DGEBA）
Amine curing agent (may have skin corrosiveness/allergenicity)
Reactive diluent
Fillers and additives
2. Determine the reporting subject
According to EU regulations, the obligation to notify can be undertaken by the following entities:
Manufacturers within the European Union
Importers within the European Union
The sole representative within the European Union (OR)
Designated responsible person of the mixture supplier (role in SCIP notification)
The solution for Chinese companies is usually to designate a sole representative within the European Union to handle UFI notifications on their behalf.
3、 UFI registration detailed process
Step 1: Preparation Phase
Data collection (recommended time: 2-4 weeks)
|Data Category | Specific Content
|Product formula | Accurate ingredients and concentration (accurate to 1%)
|Hazard Information | CLP Classification and Hazard Declaration
|Usage Description | Product Application Fields and Usage
|Toxicological data | Acute toxicity, skin irritation, and other data
|SDS Safety Data Sheet | Compliant with EU REACH format
Key Tip:
The formula information should include all ingredients, including substances with a concentration less than 1% (if the substance has a hazard classification)
Commercial sensitive information is protected by regulations and will not be publicly disclosed
Suggest using the standard format provided by ECHA (IUCLID or PCN submission tool)
Step 2: Formula evaluation and UFI generation
UFI encoding rules:
UFI consists of 16 characters in the format of XXXX-XXXX-XXXXX-XXXX
(Generated by a specific algorithm from the enterprise tax number/organization number to ensure uniqueness)
Generation steps:
1. Collect enterprise VAT number or ECHA account number
2. Use ECHA's official UFI generator or third-party tools
3. Bind UFI code with specific product formula
4. Generate a unique UFI for each formula
Notes:
Different formulas require different UFIs
When the formula change exceeds 1%, UFI needs to be regenerated
Differences in color, aroma, etc. do not affect UFI (under the same formula)
Step 3: PCN Notification Submission
Submission channel: Online submission through ECHA's Poison Centers ePporting (PCNr) system
Submit Content List:
1. Mixture identification information
Product name
UFI code
Packaging specifications and types
2. Hazard classification information
CLP hazard categories and codes
Signal words (danger/warning)
Harm to Pictograms
3. Ingredient information
Substance name (CAS number/EC number)
concentration range
Unified formula concentration
4. Toxicological information
Exposure pathway
Symptom description
First aid measures
5. Supplier Information
Announcer Information
Unique representative information of the European Union (if applicable)
Step 4: Review and Confirmation
ECHA review process:
|Stage | Time | Content
|Format review | 1-3 working days | Check if the submitted format is standardized
|Technical review | 5-10 working days | Evaluate hazard classification and formula consistency
|Confirmation notification | Instant | Send submission confirmation and file number
By symbol:
Received notification from ECHA confirming successful submission
Obtain a unique notification file number (Submission ID)
You can check the status of the notified products on the ECHA official website
Step 5: Product Identification and Compliance
UFI labeling requirements:
Must be clearly and visibly labeled on the product label
Location: Usually in Section 1 of the Safety Data Sheet (SDS)
Format: UFI: XXXX-XXXX-XXXXX-XXXX
Label Compliance Checklist:
[] Correctly label UFI on the packaging
Section 1.1 of SDS contains UFI information
[] Hazard pictograms and signal words comply with CLP requirements
[] Child safety packaging (if for consumer products)
[] Anti opening sealing label (if applicable)
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