UFI: Unique Formula Identifier

WHAT IS THE UFI NUMBER?

Over the years the authorities have tried to make increasingly important improvements in order to harmonise the system for notifying information to Poison Centres.

In 2008, CLP Regulation 1272/2008 was issued, in which Art. 45 provided for the “Appointment of bodies responsible for receiving information relating to emergency health response (Poison Centres) ".

According to the Regulation, by 20 January 2012, the European Commission was to carry out a study to assess the possibility of harmonising the type and format of the information submitted by importers and downstream users to organisations appointed to receive such information, i.e. Poison Centres.

A significant step forward was made in this regard on 22 March 2017 with the publication of Regulation (EU) 2017/542, which amended the CLP Regulation by adding Annex VIII.

Publication of this annex sought to remedy the issue of non-uniform information caused by the fact that each Member State had its own notification system based on different types of information and submission methods.

Through the reorganisation introduced by the annex, the management of information to Poison Centres became quicker and less ambiguous, thus favouring a more optimal emergency health response.

One of the innovations introduced by Annex VIII was the UFI, or Unique Formula Identifier.

The UFI is a 16-character alphanumeric code that must be specified on the label of mixtures classified as hazardous based on their health effects or physical properties.

In addition to the UFI, it will also be necessary to provide Poison Centres with information relating to the product supplier, composition, trade name and packaging, thus establishing a unique link with the product placed on the market. The condition for assigning a particular UFI is that all products labelled and notified with the same identifier have the same composition.

HOW DO I CREATE THE UFI NUMBER?

To create the UFI code, you need the company's VAT number and a mixture-specific formulation number from 0 to 268435455.

Entering these two numbers into ECHA's UFI Generator online tool will provide you with your UFI. The UFI Generator and a user guide are available on the ECHA Poison Centres website in 23 EU languages.

The code will consist of 16 characters divided into four blocks each separated by a hyphen.

MAIN INFO RELATING TO THE UFI NUMBER

• A new UFI number must be generated whenever there is a change in the composition of the mixture (if for example a component is removed, added or if the concentrations of the components change beyond the allowed range of variation).
• The UFI must be placed on the label of each hazardous mixture, preceded by the acronym "UFI" written in capital letters.
• It must be clearly visible and legible on the label and positioned so as to be easily located.

NOTE:

By derogation from Section 5.2 of Annex VIII, Section 5.3 states that, in the case of hazardous mixtures for industrial use and of mixtures which are not packaged, the UFI may alternatively be indicated in the Safety Data Sheet.

DATES TO REMEMBER

There are three deadlines by which companies are required to notify the UFI and these depend on the final use of the products and on whether or not they have already been notified to the competent body:

• 1 January 2020 (later moved to 1 January 2021) for mixtures for consumer use
• 1 January 2021 for mixtures for professional use
• 1 January 2024 for mixtures for industrial use

EXCEPTIONS

For mixtures that have already been notified, Annex VIII allows companies to avail of a transitional period until 31 December 2024. By 1 January 2025, however, these companies will also have to comply with the regulation and state the UFI on their labels.

However, if mixtures that have already been notified were to undergo changes in composition, these companies should also, for the product in question, make the notification by the appropriate deadlines.

HAS ANYTHING CHANGED FOR OUR COMPANIES IN SWITZERLAND?

The UFI was also introduced in Switzerland as from 01 January 2022.

DATES to REMEMBER

• From 1 January 2022, preparations, biocidal products and fertilisers newly placed on the market which are intended for private users must have a UFI.
• From 1 January 2022, in particular, products imported from the EEA fall into this category. This ensures that Tox Info Suisse can identify such products quickly and reliably in an emergency.
• From 1 January 2026, all other preparations, biocidal products and fertilisers that are classified as hazardous on the basis of their health and physical effects must also be in order.

NOTE:

• A UFI obtained from a manufacturer based in the European Union and indicated on products is also valid in Switzerland and must be used to notify the product to the Chemicals Product Register (RPC).
• A UFI for products placed solely on the Swiss market and not on the European market can be generated using the program made available by the Notification Authority using the Swiss VAT number. This UFI must be indicated on the product and in the Chemicals Product Register (RPC) during the procedure for announcing preparations or during the procedure for applying for the approval of biocides and fertilisers.
• Products manufactured in Switzerland or imported into Switzerland from a non-EEA country and intended, at least in part, to be exported to an EEA country. For the products to be exported to the EEA, the UFI (according to the information provided by ECHA) has to be obtained, using ECHA's UFI Generator, directly by the importer based in the EEA or on his behalf. This UFI number can also be used on products with the same composition that are marketed in Switzerland, as well as for notifying preparations to the Chemicals Product Register or during the procedure for applying for the approval of biocides and fertilisers. The European importer is responsible for making the notification to the Poison Centre in the EEA, but may delegate this responsibility to the manufacturer outside the EEA provided that the UFI matches his company (country and VAT number of the importer).
• For preparations that have already been notified to the PRC (rpc.admin.ch), it is sufficient to complete the section dedicated to entering the UFI number, if necessary; however, in the event of substantial changes it will also be necessary to update the other information in the notification and then to re-submit it.

Valentina Garbarino
CLP Responsible

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