First, let’s take a look at how the term “custom paint" is defined.
This is a paint that is formulated or produced in limited quantities.
It is also custom made for the individual consumer or professional user. And finally, it is made at the point of sale by tinting or colour mixing.
In practice, this means that the consumer or professional user comes to the point of sale, where the paint mixer prepares the paint according to their order. These are stores where you can purchase paints, while also mixing the colour to your liking. In distance sales (e.g. pre-ordering and collection at a warehouse or shop), it is considered that such paint was not made at the point of sale.
What does all this mean for the UFI code and PCN notification?
In such cases - when selling custom paints - it is not necessary to generate a UFI code and submit information to poison centres. The following applies:
With custom paints for which no notification has been made in accordance with Annex VIII to Regulation (EC) No. 1272/2008 (“CLP Regulation”) and no relevant unique formula identifier (UFI) has been generated, unique formula identifiers for all mixtures contained in a custom paint in a concentration over 0.1%subject to the obligation of notification in accordance with Article 45, shall be included in the additional information on the custom paint label, where they shall be listed together and in descending order of concentration of the mixture in the custom paint in accordance with the provisions of Section 5 of Part A of Annex VIII.
When the concentration of a mixture with a unique formula identifier in a custom pant is higher than 5%, in accordance with section 3.4 of Part B of Annex VIII, the additional information on the custom paint label shall also indicate the concentration of that mixture in addition to its unique formula identifier.
Unfortunately, I cannot give the above explanation in a more non-technical way. But by now you have realized that chemical law is quite complex. Simply writing to me could be your first step towards successfully tackling these challenges.