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Can two products have sam UFI?

This is a common question we often
get when handling with Poison Centre Notifications (PCNs). 
 
The short answer? Yes.  
 
However, as with most things, there are important details to consider. 
 
The Unique Formula Identifier (UFI) is linked to a composition of the mixture. In other words, it’s tied to specific formula. This composition can be reported either by listing the exact percentage of substances or by providing a range for each substance.  
 
The specific guidelines for these ranges are outlined in Annex VIII of the CLP Regulation (EC) No. 1272/2008. Since this is a complex topic, we won’t go into the details here.  
 
When can you use the same UFI for different products? 

In general, two products can share the same UFI if: 

  1. The products are identical in composition. For example, different brands of the same formula, also known as synonyms 
  2. The products’ composition fall within the same substance ranges as defined in Annex VIII of CLP Regulation Nr. 1272/2008 

Let’s say you’ve checked Annex VIII and confirmed that the compositions qualify to share the same UFI.  
 
What are the drawbacks of using the same UFI for different products? 

One potential issue arises with pricing. Imagine your customers find two products with the same UFI. One is sold by you at a lower price, while the other is sold by a distributor at a higher price, even though they serve the same purpose. 

Customers may realize they’re the same product (because of the same UFI) and choose to buy the cheaper option from you. 
 
What are the advantages of using the same UFI for different products? 
 
If the above scenario isn’t a concern for your business, using the same UFI across products can make things simpler. It reduces the risk of errors when submitting your PCN, as you're less likely to forget a UFI. Additionally, if products are allowed to share a UFI, you can submit just one PCN while still listing all the different trade names. If you prefer to use different UFIs, you can include them as well. 
 
In case you still need to submit your PCNs in time before the 1. 1. 2025 deadline, we can help you. Just write us at info@bens-consulting.eu and we will get back to you as soon as possible. 

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 | September 5, 2024

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