Voluntary PCN: Who gets more out of it, importers or manufacturers?

Voluntary PCN sounds simple.

Until you ask two people what it’s for.

Manufacturers use it to protect their formula.

Importers use it to meet compliance requirements with less hassle.

So who gets more out of it?

Let’s take a look. 

If you’re a manufacturer outside the EU

You aren’t allowed to submit a mandatory PCN.
But you can still support your EU partners with a voluntary one.

Here’s what you get out of it:

• You don’t have to reveal your full formulation
• You keep things consistent across all countries
• You help your customers with their compliance work

But there are trade-offs:

• Importers still need to submit their own PCNs
• Your UFI cannot appear on the product label
• You’re paying for something that doesn’t replace your customer’s obligations

If protecting your formula is your top priority, it’s still a smart move. 

If you’re an importer based in the EU

You’re the one responsible for compliance.
A voluntary PCN can make things easier, but not complete.

Here’s where it helps:

• You can use the UFI without seeing the full formula
• You have less work collecting data
• You don’t have to push your supplier for sensitive information

But here’s what it won’t do:

• It won’t cover your legal obligations
• You still need to submit your own PCN
• You can’t use the supplier’s UFI on the label

In other words, it’s helpful but not a shortcut. 

Who benefits more?

Both sides benefit, but in different ways.

Manufacturers stay in control of their intellectual property. Importers get a lighter compliance burden.

It only works when both parties are aligned. That means clear communication, good timing, and agreement on who is responsible for what. 

Action Point

If you’re a manufacturer, think about submitting a voluntary PCN and giving your importers the UFI. This gives you control while helping your customers comply.

If you’re an importer, ask for the UFI and make sure you know what your own obligations are. The voluntary PCN helps, but it doesn’t replace your work.

In the next article, we’ll tackle a common myth: that the UFI is all you need.

Spoiler alert: It’s not.