The entire question I received is actually a bit longer and reads as follows:
"Can we generate the UFI ourselves (the generator is fairly simple) or do we need any further registration by country for which we would need, say, you?"
Because I believe the answer is useful to anyone encountering the subject of UFI and PCN, I share it with you in its entirety:
"You can generate the UFI code yourself because it is really an easy process. However, you should note that this is just one of many steps that need to be taken in the new process of submitting information to poison centres. The UFI code in itself is meaningless and may be called "empty" if no PCN notification has been performed for it.
A so-called "empty" UFI code can cause problems, for example, for downstream users. Let's look at a quick example: a downstream user (formulator) can use your mixture as a mixture in mixture and must be informed if information about this mixture in mixture has not yet been provided. The downstream user cannot use an "empty" UFI code for its submission of information, as poison centres cannot establish a link to the complete information about the mixture in case of an accident.
You also need an overview of which mixture matches a particular UFI code.
PCN notification or notification to poison centres must, therefore, be linked to this specific UFI code (otherwise the UFI code is "empty" as already mentioned).
PCN notification is a process by which information on a dangerous mixture is submitted to a poison centre in each Member State of the European Economic Area.
With this process, a specific chemical composition of the mixture is linked to a specific UFI code.
Then, you need to regularly and closely monitor any changes and updates related to this code.
The notification is made in a software tool issued by ECHA (European Chemicals Agency).
A PCN file is created, which contains a lot of other information about the chemical in addition to the composition data, and is submitted to the database of poison centres.
This is followed by regular monitoring and, if necessary, updating of the PCN file."
Since there is a lot of information in this article, I present a graphical representation of the PCN process step by step below (generating a UFI code is only a part of this process):
If you do not know where to start or do not have the time to perform this PCN notification efficiently and correctly (and also update it), it may be time to contact me at simona@bens-consulting.
Just contacting me costs you absolutely nothing - but it can save you a lot of trouble in January 2021.