One of the most common mistakes when using a UFI code is the appearance of a so-called "empty" UFI code. Let's see what this actually means.
The UFI code is "empty" if no PCN notification has been submitted for it and / or no mandatory reporting of data on the hazardous properties of the mixture has been made to the poison centre. You can find the October overview of countires accepting PCN notifications here.
The UFI code is generated with the UFI generator. You should be aware that the UFI generator is only a tool that allows you to obtain a UFI code. A generated UFI code WITHOUT a PCN notification has no "content".
Let's now look at a concrete example with the consequences of using an "empty" UFI code.
Determine a "blank" UFI code for your A mixture and add it to the label. It is therefore a UFI code without a PCN notification. You sell mixture A, which is marked with an "empty" UFI code, to your customer, who uses it as a raw material in the preparation of his mixture B. For mixture B, your customer (formulator) must complete a PCN notification and needs information about the raw materials or UFI numbers from raw materials.
However, the information on your mixture A has not yet been submitted to the EU Poisons Center and therefore the formulator is dealing with an "empty" UFI code that he found on your label. He would, of course, like to use in the PCN notification of his mixture B. However his PCN notification is unsuccessful due to your "empty" UFI code.
An "empty" UFI prevents Poison Centers from establishing a link to complete information about the mixture in the event of an accident. Therefore, the formulator (the downstream user of your mixture A, who uses it as a raw material) cannot use your UFI code when performing the PCN notification of his mixture B, because it is "empty".
In order for him to successfully perform a PCN notification for his B mixture, you must inform him of the 100% composition of your A mixture. If you want to know what information are required to perform a successful PCN notification then this post is for you.
To avoid this, the best solution is not to generate an "empty" UFI code, but to perform a full PCN notification for your mixture. In this case, it is not necessary to communicate 100% of the composition of your mixture to formulators who use your mixture to produce new mixtures.
If you don't know where to start, or you don't have the time to effectively and correctly implement (and update) this PCN notification, it might be time to write to me at simona.miklavcic@bens-consulting.eu.
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