One of the most common (and valid) questions related to the yearly voluntary submission representation fee we charge to non-EU companies is:
“What happens if we stop using your representation after one or two years—or decide to change?”
Here’s how we handle it and what I believe works well for our clients as well:
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If you no longer need representation
We support voluntary UFI/PCN submissions through representation for as long as you need them. If at some point you decide that this is no longer required, you can request the cancellation of the representation. Once representation is cancelled, the related account is closed, and we will no longer support the voluntary UFI.
That said, we do not recommend this step lightly. Cancelling the submission too early can create issues—your products might still be on the EU market, and withdrawal of the notification can trigger problems with poison centres. For example, downstream users who have linked their UFI to yours may receive warnings during their next dossier update, informing them that your voluntary UFI is no longer valid.
If you are considering cancelling, we’re happy to talk it through first to ensure it’s the right decision and to avoid potential complications.
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If you appoint a new representative
Your new representative will need to prepare and submit their own PCN dossiers. Once that’s done, we can deactivate or cancel the ones we submitted.
The UFI code itself can stay the same if the new submission is aligned — but it must go through the new representative’s ECHA account.
Our role is to make the transition smooth, transparent, and safe for your business.
If you're thinking long term, it's always smart to understand the exit route before you enter.
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