What is the EU CLP-PCN-UFI registration process?
Date：2025-02-12 09:51:55 Classification
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The EU CLP-PCN-UFI registration process is a management measure implemented for hazardous mixtures placed on the EU market in accordance with the requirements of the Classification, Labelling and Packaging of Substances and Mixtures Regulation (CLP Regulation). The following are the specific processes and key points:
I. Determine the scope of application of the product
1. Applicable conditions
All of the following conditions must be met:
- The product is a chemical mixture (such as adhesives, cleaners, detergents, fuels, etc.);
- Classified as a physical or health hazard (such as flammable, corrosive, carcinogenic, etc.);
- The product needs to be placed on the EU market (including consumer, professional or industrial use).
2. Exemptions
Mixtures that are not classified as hazards do not need to be registered, but it should be noted that some low-concentration hazardous substances may still need to be labeled.
II. Collect necessary information and documents
1. Product information
- Product name, description and formula (ingredient name, concentration, hazard characteristics);
- If the formula needs to be kept confidential, a UFI can be generated through a third-party agency to avoid disclosing specific ingredients.
2. Company information
- Company name, address, contact information and EU VAT number (for generating UFI).
3. SDS (Safety Data Sheet)
- An SDS report that complies with the latest EU regulations ((EU) 2020/878) must be provided, which must include UFI code, nanomaterial information, endocrine disruption characteristics, etc.;
- After January 1, 2023, failure to update the SDS will result in the product being unable to enter the EU market.
III. Generate UFI code
1. UFI format
- Consists of 16 alphanumeric characters in the format of `UFI: XXXX-XXXX-XXXX-XXXX`;
- Generated based on the company's VAT number and internal code to ensure uniqueness.
2. Generation method
- Generate online through the EU official or third-party platform, ensuring that products with the same formula use the same UFI, and a new UFI is required if the formula changes.
4. Submit Poison Center Notification (PCN)
1. Notification Content
- Submit the hazard information, UFI and company contact information of the mixture through ECHA's IT tool;
- Must be consistent with the UFI in the SDS.
2. Time Cycle
- It usually takes 5-7 working days to generate UFI and complete PCN notification.
5. Label and Compliance Management
1. Label Requirements
- UFI must be printed or affixed to the product label. If the product is unpackaged (such as industrial bulk products), it must be indicated in the SDS;
- The label must comply with the format and content requirements of the CLP regulations (such as hazard pictograms, warnings, etc.).
2. Subsequent Maintenance
- When the formula changes, the UFI must be regenerated and the notification updated;
- Regularly check the compliance of SDS and labels to avoid violations due to regulatory updates.
VI. Notes
- Non-EU companies can entrust a third-party agency in the EU to register on their behalf to protect trade secrets;
- The UFI labeling requirements for industrial mixtures will be fully implemented from January 1, 2024.
Through the above process, companies can ensure that their products comply with EU regulations and avoid market access barriers. Specific operational recommendations are combined with guidance from professional agencies to improve efficiency and reduce compliance risks.
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