Disclaimer: The information in this article presents our understanding and views and is not legal advice. If you need more details on any legislation or legal advice about what action to take when labelling your products, please contact an adviser or solicitor.

What is a UFI?

A UFI (Unique Formula Identifier) is a 16-digit alphanumeric code that is now a requirement on CLP labels as part of a recent amendment to EU CLP. Along with this, there is the requirement to notify your products to the relevant Poison Centre of the country you intend to sell in. You notify the products in the form of a Poison Centre Notification product dossier. The PCN product dossier requires the following information:

a). The UFI of the mixture to be notified. This links the information in the PCN to the physical product, as the UFI is required on the CLP label. The same UFI can be used for multiple products, if the mixture composition is the same (for example 9cl, 20cl and 30cl candles can all have the same UFI). Even if the branding/trade name is different, the same UFI can be assigned, however, you can choose to assign different UFI’s to each product if that’s your preference. The UFI must be prefaced with ‘UFI:’ on the CLP label.

b). A full chemical composition should be provided (or as full as you can), with concentrations or concentration ranges for hazardous and non-hazardous components being stated. In the case of candles/diffusers etc, the MiM (Mixture in Mixture) method may be used. You also need to add the information on your wax/base (CAS number, name etc).

c). The classification and labelling (CLP info) for the final product and the classification info on substance and MiM components (including the substances within the MiM). For wax, this would just be N/A or ‘Not classified’ and the substance/MiM substance CLP info will be included on the SDS, in Section 3.2.

d). Toxicological information for the final product – available in Section 11 of the SDS.

A product category should be assigned based on the products main intended use and identifying details such as trade name, packaging type, packaging sizes, colours etc should be assigned. Once all this information is together, you can either prepare and submit the dossier via ECHA's submission portal (if the country has signed up to be notified this way) or you can prepare the dossier offline, in line with the PCN format, and notify the individual Poison Centres in line with how that country accepts notification.

When do you need a UFI?

Mixtures that are classified as either a human health hazard or a physical hazard require a UFI on the CLP label and a PCN. Mixtures classified as environmental hazards only can be notified on a voluntary basis.

Where can I generate a UFI?

These can be generated via ECHA’s UFI tool. Note that you do not need a VAT number to generate a UFI.