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The big mistake with Voluntary PCNs

It happens more than you'd think.

A company submits a voluntary PCN. They get a UFI. They feel like compliance is sorted.

It’s not.

A voluntary UFI is useful, yes. But it is not enough.

Let’s look at what it actually does. And what it doesn’t. 

What a voluntary UFI can help with

  • Gives importers a reference point when submitting their own PCNs
  • Keeps your full formula private
  • Makes supply chain compliance a little smoother, especially across multiple countries

It’s a smart tool. But it only works if everyone understands what it is. And what it is not. 

What a voluntary UFI cannot do

  • You cannot print it on your product label
  • It does not remove your importers’ obligations
  • It can create confusion if someone assumes it’s a complete solution

And that’s the problem. Some importers assume the UFI means they’re compliant. They are not.

That assumption can cost you time, money, and trust. And possibly more. 

How to avoid this

Start by talking.

Make sure your importers understand what you are giving them. And what they still need to do.

Have a clear plan in place for who submits what. And when.

If you want your UFI to be valid for labelling, an EU-based entity must submit the full PCN. That should be your importer, or in some cases a distributor. 

Final thought

Voluntary PCNs are part of the solution. Not the whole solution.

If you want them to work, you need to build them into your wider compliance plan. That means clarity, coordination, and constant communication.

In the next post, I’ll walk you through how to submit a voluntary PCN the right way. Step by step, with zero guesswork.

Disclaimer:
Information on this blog is prepared with utmost care, but it is not about (chemical) consulting, and the provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can write to us at bojan.dimic@bens-consulting.eu
UFI / PCN | June 6, 2025

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