Guide to EU CLP-PCN-UFI Registration for Cleaning Products
Date：2026-09-14 11:11:38 Classification
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Guide to EU CLP-PCN-UFI Registration for Cleaning Products
I. Why is PCN-UFI registration mandatory for cleaning products?
Under Annex VIII of the EU CLP Regulation, products such as household cleaners, kitchen cleaners, bathroom cleaners, laundry detergents, dishwashing liquids, floor cleaners, bleaches, and disinfectants are subject to mandatory notification requirements. This is because cleaning products commonly contain:
Surfactants (e.g., fatty alcohol ethoxylates) – Eye and skin irritants
Solvents (e.g., isopropanol, ethanol) – Flammability hazards
Acids/Alkalis (e.g., citric acid, sodium hydroxide) – Corrosive hazards
Chlorides (e.g., sodium hypochlorite) – Acute toxicity and corrosive hazards
Fragrances and preservatives (e.g., methylisothiazolinone/MIT) – Sensitization hazards
E-commerce sellers, cross-border sellers, and brand exporters who sell cleaning products in the EU without completing the PCN notification face potential fines of up to €50,000 and the risk of having their products removed from the market. II. Five-Step Processing Procedure (Detergent-Specific Version)
Step 1: Generate a unique UFI for each detergent product
Access the UFI Generator on the ECHA official website.
Input: Your company's VAT number + Formula number (any number from 1 to 268).
The system generates a 16-character hexadecimal code (e.g., R53N-8X1P-G3V6-7K4M).
Key Principles:
Different formulas → Different UFIs (e.g., "Lemon-scented" and "Lavender-scented" dishwashing liquids require separate UFIs).
A new UFI must be generated if the formula is updated.
The same UFI applies to the same detergent product across the entire EU.
Step 2: Determine the CLP classification of the detergent
Common hazard classifications for detergents include:
| Hazard Type | Typical Scenario
| Eye Irrit. 2 (Eye Irritation) | Dishwashing liquid containing anionic surfactants
| Skin Irrit. 2 (Skin Irritation) | Degreaser containing alkaline ingredients
| Acute Tox. 4 (Oral) | Drain cleaner containing toxic ingredients
| Skin Corr. 1 (Skin Corrosion) | Highly acidic toilet cleaner, bleach
| Aquatic Chronic 3 (Chronic Aquatic Toxicity) | Most detergents containing surfactants
| Flam. Liq. 3 (Flammable Liquid) | Glass cleaner containing high concentrations of alcohol
Even if a product is not classified as hazardous (e.g., certain detergents with purely plant-based formulas), it is still recommended to submit a PCN notification if entering the EU market, in order to comply with regulatory requirements. Step 3: Create an ECHA Account
Log in to the ECHA Submission Portal
Select the role: "Manufacturer," "Importer," or "Downstream User"
Prepare the following information:
Company business license and EU VAT number
Legal entity representative information
Administrator email address (for receiving notifications)
Review period: 3–10 working days
Step 4: Complete the Dossier via IUCLID (Core Step)
Key information required for detergent products:
1. Basic product information
Product name, trademark, product code
UFI code, color, and scent (if applicable)
Physical state (liquid/powder/gel) and packaging type
2. Full ingredient disclosure
CAS number, EC number, and concentration range for all ingredients
Must list all ingredients, even those classified as "non-hazardous"
Example: Fatty alcohol polyoxyethylene ether (CAS: 9002-96-0), concentration 1–5%
3. CLP classification
Hazard statements (e.g., H318: Causes serious eye damage)
Signal word (Warning / Danger)
Pictograms (e.g., GHS05 Corrosion, GHS07 Exclamation mark)
4. Toxicological data
Acute Toxicity Estimate (ATE)
LD50/LC50 values for each ingredient
5. Labeling and packaging details
Packaging capacity and material
Sales channel (consumer use / professional use)
It is recommended to use ECHA’s free official software, IUCLID 6, for data management to facilitate batch notifications for multiple products.
Step 5: Select target markets and submit
Notification must be made to the poison center of the specific country where the detergent is marketed
Major markets: Germany, France, Italy, Spain, the Netherlands, Poland, etc.
Fees apply in some countries (e.g., France, Hungary), ranging from approximately €50 to €500 per product per country
Upon submission, a Submission Number is issued as proof of compliance
III. UFI Labeling Compliance Requirements for Detergents
The UFI must be printed clearly and indelibly on the product packaging:
✅ Example of correct format:
UFI: R53N-8X1P-G3V6-7K4M
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