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Can one UFI cover all EEA countries?

This question comes up again and again.

A company generates a UFI and prints it on the label.

Then they ask, “Are we good for all countries now?”

It sounds logical. But the answer isn’t that simple.

Let’s clear it up. 

Can a single UFI be used in every EEA country?

Yes, technically. But only if certain conditions are met.

Here’s what matters most:

The UFI must be linked to a valid PCN submission in every country where the product is sold.

The UFI itself doesn’t guarantee anything.

The PCN submission does

When does it work across multiple countries?

  • If you submit an EEA-wide PCN, the UFI is valid in all selected countries
  • If each importer submits a country-specific PCN using the same UFI, it can also work
  • If you’re a non-EU company, a voluntary PCN can support your customers by standardizing the UFI they use

So yes, a single UFI can cover all EEA markets. But only if it’s submitted properly.

Where things fall apart

  • If a UFI is printed on a label without a valid PCN behind it, it’s useless
  • If you rely on one importer to notify but sell in five countries, the other four might not be covered
  • If local rules add requirements and you skip them, your compliance is incomplete

And here’s the big one:

If Poison Centres can’t access the data behind the UFI, it might as well not exist. 

What’s the right strategy?

If you have an EEA-based legal entity, go for an EEA-wide PCN. That gives you full coverage with one action.

If you use multiple importers, make sure each one submits a PCN with the correct UFI for their market.

If you’re a non-EU manufacturer, use a voluntary PCN to give your importers a shared UFI. Then help them complete their own submissions.

Final thought

The UFI is just a code.

It becomes valuable only when it’s backed by the right PCN submissions in the right countries.

If not, it’s just ink on a label.

And that won’t help the Poison Centre in an emergency.

In the next article, we’ll look at one of the biggest reasons companies choose voluntary PCN: protecting their formulation.

And why it’s often the smartest move they can make.

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 12, 2025

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