The main change: a harmonised format
From 1st January 2021, importers and downstream users are obliged to notify their mixtures classified as hazardous to consumers and professionals in a new PCN format. However, the deadline for mixtures for industrial use is 1st January 2024. This is an important change for all companies placing their products on the European market.
The information required for the harmonised PCN notification is detailed in Annex VIII of the CLP (Classification, Labelling and Packaging) Regulation:
- Company details
- The UFI
- Information on the mixture itself (classification, translated labelling elements and toxicological information, pH, form, physical state, integral composition of the mixture)
- Product information (name and description, general public, professional or industrial use, type of packaging and size, product category, colour)
- Classification and labelling
- Toxicological information
All this information must, of course, be updated in the event of any changes.
If the mixture was already previously on the market and notified to the local poison control centre of the Member State, the date of compliance is 1st January 2025.
EcoMundo can support you in your efforts to comply with the CLP Regulation, from the notification strategy to the optimisation of your internal resources.
Generating the UFI: the first step towards compliance
Since that date, it has also been necessary to update the labelling of hazardous mixtures for consumers and professionals to include a UFI (Unique Formula Identifier).
The UFI is a set of numbers and letters linked to a declaration. It establishes a link between the information provided on the notified mixture and the products placed on the market. It enables a product to be quickly identified and an appropriate response to be provided in the event of a health emergency. The UFI has no value if it is not linked to a declaration, and the mixture to which it refers will not be considered as compliant without it.
ECHA has made available a very user-friendly UFI generator. You need to go to the UFI Generator and provide your company's VAT number and the formula number(s) of your products. You then just have to enter them and click on "Create".
Why harmonise the format for reporting to the Poison Control Centres?
Before the harmonised format came into force, the information given during a health emergency varied from one Member State to another.
These new information requirements therefore help to harmonise and reduce inconsistencies in the information available to medical staff in case of an emergency.
However, countries remain free to choose whether or not to connect to ECHA's notification platform to support the process. ECHA has also put online a publication listing the progress made by the different countries in connecting to the platform to facilitate compliance by companies.
Wish to know more about poison centres notification?
For more information, do not hesitate to contact Renaud Germain-Thomas or one of our experts !
