GB 4806 Report on Aluminum Food Containers (Food Contact Materials)
Date：2026-10-14 09:45:54 Classification
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Whether dehydrated products require PCN-UFI registration under the EU CLP Regulation depends on the specific nature of the product. The following provides a systematic explanation covering applicability, the registration process, and key elements.
I. Determining Applicability: Do Dehydrated Products Require PCN-UFI Registration?
The CLP Regulation (EC 1272/2008) and the PCN-UFI system (introduced in 2021) primarily target chemical mixtures placed on the EU market, rather than ordinary dehydrated food products. Registration is required if your product falls into the following categories:
1. Common scenarios requiring registration
Desiccants/Dehumidifiers: Silica gel desiccants, molecular sieves, quicklime desiccants, etc.
Dehydrated chemicals: Anhydrous sodium sulfate, anhydrous citric acid, drying reagents, etc.
Industrial dehydrated mixtures: Dehydrating cleaning agents, dehydrating solvents, etc.
Special-purpose mixtures: Laboratory dehydrating agents, dehydrating products for chemical processing.
2. Scenarios generally not requiring registration
Dehydrated foods (e.g., dried fruits/vegetables, jerky, seasonings)—governed by food regulations.
Dried cosmetic products—governed by the Cosmetics Regulation (EC 1223/2009).
Dried pharmaceutical products—governed by pharmaceutical regulations.
Key criterion: Whether the product is classified as a "chemical mixture" and carries a hazard classification (health, physical, or environmental hazards). If the product has no hazard classification, it may fall under the scope of non-hazardous substance notification or be exempt.
II. Explanation of Key Concepts
1. CLP Regulation (Classification, Labelling and Packaging)
The EU Regulation on the Classification, Labelling and Packaging of substances and mixtures; it represents the implementation of the GHS (Globally Harmonized System of Classification and Labelling of Chemicals) within the EU.
2. PCN (Poison Centre Notification)
Poison Centre Notification involves submitting product formulation information to poison centres in EU member states for use in medical emergencies. 3. UFI (Unique Formula Identifier)
A 16-character alphanumeric code printed on the product label, used for the rapid identification of the product formula in emergency situations.
4. Scope of Application
Mixtures classified as hazardous due to health or physical hazards.
Mixtures containing specific substances (e.g., activated carbon, flame retardants) that are classified as hazardous due to health or physical hazards; notification is required even if the mixture itself is not classified as hazardous.
III. Submission Process
Step 1: Product Classification and Determination (1–2 weeks)
Classify the product's hazards in accordance with the CLP Regulation.
Assess whether the product falls within the scope of PCN notification.
Determine the UN Number for the product (if applicable).
Step 2: Generate UFI Code (1 day)
Create a 16-character UFI using the UFI Generator (provided on the ECHA website).
A unique UFI corresponds to a specific formula; a new UFI must be generated if the formula changes.
Step 3: Prepare Submission Dossier (2–4 weeks)
Core information includes:
Basic product information: Product name, trade name, color, physical state, odor, pH value, etc.
Complete composition/formula: Names of all ingredients, CAS numbers, EC numbers, and concentration ranges.
Hazard classification information: GHS classification, hazard statements (H-statements), and precautionary statements (P-statements).
Toxicological information: Data on acute toxicity, dermal toxicity, inhalation toxicity, etc.
Packaging information: Packaging type and capacity.
Market placement information: Date of first placement on the market and target EU Member States.
Step 4: Select Submission Method (Critical Step)
Method 1: Online Submission (Recommended)
Via ECHA Submission Submission via the ECHA Submission Portal
Supports bulk upload in XML format
A single submission can cover multiple EU Member States
Method 2: Member State Poison Centre Systems
Some countries maintain independent systems (e.g., France, Germany, the Netherlands)
Requires interfacing with each country's system individually
Step 5: Fee Payment (Case-dependent)
Unified ECHA submission: Free (though costs apply for XML software tools or engaging an agent)
Separate Member State submissions: Fees apply in some countries (e.g., Belgium, Ireland)
Fees vary based on the Member State and product complexity
Step 6: Affixing the UFI to the Label (Ongoing Compliance)
The UFI must be printed clearly, legibly, and indelibly on the product label
The UFI must be placed in a visible location
For multi-layer packaging, the UFI should be placed on the inner or outer layer that is in direct contact with the product
IV. Estimated Timeline and Costs
| Item | Timeline | Cost Range (RMB) |
| Product classification assessment | 5 working days | 1,000–2,000 RMB |
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