"Our supplier has packaging already printed with a UFI code - can we just use that?"
Short answer: sometimes. But there are risks. I know this sounds like I’m avoiding the answer but let me explain.
If the original UFI was created by a different company (say, a German supplier), and your formulation doesn’t perfectly match theirs, you could get flagged by authorities.
Even small differences - like a 1% shift in a non-hazardous component - can trigger a warning on ECHA Submission Portal. Especially in countries like Germany, where the BfR monitors dossiers closely you could face additional questions.
So, while keeping the existing UFI might feel like the easy way out, in practice it often causes more complications than it's worth.
Our advice? Start fresh with a new UFI and a clean PCN under your own name. That way, your product is fully compliant and independent.
We’ve helped dozens of companies in this exact situation. Let’s chat and find the right path for you.
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