Many companies assume that submitting a voluntary Poison Centre Notification (PCN) and obtaining a Unique Formula Identifier (UFI) will be enough to ensure compliance.
However, a voluntary UFI is not a silver bullet. It’s important to understand what it does—and, more importantly, what it doesn’t do.
What a voluntary UFI can do?
✅ Supports importers by providing a reference – A voluntary UFI allows manufacturers to share a compliance reference with importers, making it easier for them to complete their own notifications.
✅ Protects composition confidentiality – Instead of disclosing full ingredient details to importers, manufacturers can use a voluntary PCN to maintain control over proprietary information.
✅ Facilitates smoother supply chain operations – For businesses working with multiple distributors across the EU, a voluntary UFI ensures that compliance processes are at least partially streamlined.
What a voluntary UFI cannot do
❌ Cannot appear on product labels – Only a UFI generated through a legally required PCN (submitted by an EU entity – duty holder) can be used on product packaging.
❌ Does not exempt importers from their obligations – Even if a manufacturer submits a voluntary PCN, importers must still complete their own PCN submissions for each country where the product is sold.
❌ May lead to confusion in the supply chain – Importers unfamiliar with voluntary PCNs may incorrectly assume they are fully compliant, leading to regulatory risks and potential penalties.
How to avoid this pitfall
To ensure that your voluntary PCN is useful and does not cause compliance issues:
Communicate clearly with importers – Make sure they understand that they still have submission obligations, even with a voluntary PCN.
Coordinate compliance strategies – Work with importers and distributors to establish a clear plan for who submits what and when.
Consider EU-wide PCN submission – If you want a UFI that is valid for labeling, ensure that an EU entity (importer, distributor, or consultant) submits a full PCN covering all relevant markets.
Final thoughts: Is a voluntary UFI worth it?
A voluntary UFI can be a useful tool, but it does not replace regulatory obligations. Companies should view it as part of a broader compliance strategy rather than a one-step solution.
In the next post, we’ll break down the step-by-step process of submitting a Voluntary PCN and how to do it effectively.
P.S.: You can read the first two posts here and here.
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