Protecting your formula: Is voluntary PCN your best move?

One of the biggest concerns for manufacturers is this:

“We want to stay compliant…

But we don’t want to hand over our full formula.”

If that sounds like your situation, a voluntary PCN might be exactly what you need.

It helps you stay in control. Without giving away your secrets.

Here’s how it works. 

What a voluntary PCN does for your confidentiality?

When you submit a voluntary PCN, the product composition goes directly to the authorities.

You don’t have to share full ingredient details with importers, distributors, or customers.

You provide them with a UFI instead.

That UFI links to your registered data. It keeps your formula protected and helps them meet their obligations. 

Why companies choose this path?

• The full formulation stays with you
• Your importers get what they need without seeing sensitive information
• You reduce the risk of someone accidentally (or intentionally) disclosing what’s in your product

It’s a smart balance between transparency and protection. 

Who benefits most?

Voluntary PCN is ideal if:

• You’re a non-EU manufacturer trying to simplify life for your EU partners
• You have proprietary formulas you don’t want circulating beyond your control

In both cases, this option gives you flexibility without compromising confidentiality. 

What it won’t do?

• It won’t replace your importers’ responsibilities. They still need to submit their own PCNs.
• The UFI cannot go on the product label unless the PCN is submitted by an EU-based duty holder.
• You’ll need an EU or EEA-based legal entity to make the submission. If you don’t have one, you’ll need a partner like us to act on your behalf.

So it’s not a shortcut. But it is a shield.