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UFI and PCN has become a reality in 2021.

As expected there are some difficulties when it comes to understanding and fulfilling these obligations.

But two mistakes come out regularly when dealing with clients. Both can cost you lots of money and hard-earned reputation.

First costly mistake is called »empty« UFI code or »empty« UFI identifier.

This is when you generate UFI code using UFI generator. You than add this newly generated UFI code to your label thinking this wasn't all that hard.

In reality you did next to nothing as UFI generator is just a tool allowing you to obtain a UFI code. Sure you get a 16-character code called the unique formula identifier (UFI), but this code is »empty« because no PCN notification has been submitted for it. And consequently, no mandatory reporting of data on the hazardous properties of the mixture has been made to the Poison Centre.

In this respect, UFI generator tool doesn't check whether this particular newly created UFI code is linked to any specific PCN notification. Nor does it check if has been successfully implemented at all.

Obtaining UFI code is a start, but you still need to do the hard of PCN notification yourselves. (If you need help with that just write me a short e-mail).

Second mistake is doing PCN notification for just one country thinking this is now valid for all the markets where you sell your products.

It's not. You need to do PCN notification for every country individually. This is also one of the reasons why ECHA went for a harmonized format when it comes to submission information in various Poison centers. More on how to prepare and submit information to poison centers in this ECHA brochure.

If you do not know where to start or do not have the time to perform UFI and PCN notifications efficiently and correctly (and also update it), it may be time to contact me.

Just contacting me costs you absolutely nothing, but it can save you a lot of time and money.  

Disclaimer:
Information on this blog is prepared with utmost care, but it is not about (chemical) consulting, and the provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can write to us at bojan.dimic@bens-consulting.eu
UFI / PCN | June 21, 2021

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