A recent client asked:
"We already have UFI codes, we just want to update the product names. Do we need to do a whole new PCN?"
Great question. And the answer depends on the scope of the update.
When is it just an update?
If the product chemical composition stays the same (or changes only inside the possible defined ranges for each chemical substance in a mixture) and you're only tweaking the trade name or packaging, then it's considered an update. Or if you extend the marketplace to more Member States. We do this all the time for our clients.
When is it necessary to generate new UFI and submit a new PCN?
If there’s a change:
- of components (addition, substitution or deletion of one or more components) - this applies to the components which are required to be indicated in the PCN);
- in concentration beyond the concentration range provided in the original PCN;
- in concentration beyond the limits allowed for declared concentrations;
- in the composition of a mixture that conforms with a Standard Formula in a way that it does not conform to that Standard Formula anymore;
- in the composition of a fuel in a way that Section 3 of the SDS requires update.
Most of the changes above occur:
- due to changes of materials, you use (e.g. change of one material with a similar one, but different in terms of chemical identity – CAS, EC number or hazards);
- due to changes in formulation themselves – you tweak the % of raw materials and the final concentration of substances are beyond the possible limits allowed.
Then that’s a new PCN, and everything needs to be done accordingly.
Why does this matter?
Because the ECHA system treats these differently, and regulators will expect consistency across your SDS, labels, and PCN records.
Pro tip: Keep your internal records clear. It helps you avoid overpaying and repeating work — and helps us help you faster. Now, if you need our help, we’re just one phone call or e-mail away.
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