Understanding your UFI responsibilities: how to navigate PCN notifications for branded mixtures

When bottling mixtures from a partner but using your own brand names, you might wonder about the need for a unique UFI code.

Here’s a question I received recently:

“We’re bottling our partner’s mixtures, but we sell them under our own brand names. Our partner mentioned we could just use their UFI code. Can we go that route?”

If you’re bottling mixtures under your brand names, this makes you a duty holder (downstream user) under Annex VIII and Article 45 of Regulation EC No. 1272/2008 (CLP Regulation). Here’s what that means for your UFI code and Poison Centre Notification (PCN) responsibilities.

According to regulatory guidance, you have two main options:

1. Partner Collaboration: Ask your partner to include your brand names, packaging information, and even unique UFIs (if needed) in their notifications for each market where you’ll sell the product.
   This approach is typically simpler but requires agreement from your partner. If they’re willing to cooperate, this route may save you time and effort.
2. Independent Notification: Submit your own stand-alone notifications. This approach gives you control over the process but requires additional steps to meet compliance independently.

The first option is often the easiest and most efficient but be sure to check with your partner to confirm they’re open to this arrangement. If not, you’ll need to proceed with option two to ensure compliance.