UFIs and PCNs demystified: when are they really necessary?

If you’ve ever wondered whether you need to submit a Poison Centre Notification (PCN) or assign a Unique Formula Identifier (UFI) to your product, you’re not alone. The rules can seem overwhelming, but they boil down to a simple principle: it depends on whether your mixture is classified as hazardous. 

Let’s break it down step by step. I do apologize if some of the steps seem childishly simple, but I want to write this post in a way that helps everyone – from a beginner to someone who has just this one deceivingly simple question in mind.  

The first step is knowing what UFIs and PCNs are. Here's a quick condensed two-bullet points answer:  

• UFI: A 16-character alphanumeric code that uniquely identifies your chemical mixture. It ensures quick identification in emergencies. 

• PCN: A regulatory requirement to notify poison centers about hazardous mixtures to support emergency health responses. 

The second step is giving you a quick rule to help you decide when you need them. 

You need to answer these two quick questions:  

1. Is my mixture classified as hazardous to health? 
   -Look for H3xx hazard codes (e.g., H315, H318) or EUH380, EUH381 on your Safety Data Sheet (SDS). 
2. Does my mixture have physical hazards? 
   -Check for H2xx codes (e.g., H226, H242) on your SDS 

If you answered “yes” to either of these two questions, an UFI and PCN are mandatory. There are some exceptions if you have gases under pressure or explosives only. For these you do not need UFI and PCN. 

If “no”, like in cases where the only label is “EUH210,” you’re off the hook—though voluntary submission is always an option for added safety or transparency. 

Now if this all sounds to hypothetical, then this real-life example might help.  

Take this scenario: A client noticed their mixture only carries the EUH210 label, which reads, “Safety data sheet available on request.” They weren’t sure if they needed a PCN. The answer? No. Since the mixture isn’t classified with H3xx (or EUH380, EUH381) or H2xx codes, it falls outside the mandatory notification requirements. 

That's all fine, but I still have my doubts about how this applies to my product portfolio I hear you say. Then you can write to me at Luka.Rifelj@bens-consulting.eu and we'll help. 

Mistakes can happen, and the penalties for non-compliance are steep. If you're unsure about your classifications or notifications, consulting an expert like us can save you a lot of headaches.