Products’ composition has changed – do we relabel old products with new UFI code?

 We’re always chasing interesting questions where we can help and make life a bit easier.

I found the following question on ECHA LinkedIn Group. And since not everybody is closely following these groups, I decided to share my thoughts and recommendations on this situation.

Now, here’s the situation and UFI in question:

“If a product has a new composition, this must be reported. You get a new UFI.

However, there are still goods in the warehouse that still have the old UFI tagged. The new UFI is automatically added to the SDS. Does it have to be relabeled every time there is a new UFI?

This is a great effort and extremely difficult to handle logistically. How do other companies deal with this?”

Here’s my answer – hope it helps you if you face similar situation:

“The UFI should always correspond the composition. That means if there is no change in the "old" composition you should not relabel the old composition with the new UFI.

There is one exception though. You can relabel it if the new composition is also within the PCN ranges of the "old" notification. In such case you could of course freely change the UFI also on the "old" composition (but not necessary).

However if the old UFI's composition is not within the range of the composition behind the new UFI, then I would not relabel the "old" products with the new UFI as it would be wrong to do so.”

You can find many more blog posts if you’re struggling with UFI and PCN notifications here.

Or you can simply drop me an email – luka.rifelj@bens-consulting.eu - and see how your challenges go away like a shadow in the night.

Author of the original photo Tiger Lily from Pexels