Recently, we received an email from a U.S.-based manufacturer of ceramic glazes. Their situation is one that many non-EU companies face when entering the European market, so I think it’s worth sharing here (without names, of course).
Here’s the challenge they described:
“We manufacture ceramic glazes in the U.S., which are imported into the EU by multiple distributors. Some of our products are classified as hazardous and require PCN notifications. We’ve started looking into voluntary PCNs, but one of the issues is which UFI to print on the label. Can we use a single UFI from a voluntary notification for all importers, or does each importer need to generate their own?”
This is a very common question — and the answer isn’t as straightforward as many hope.
The UFI Puzzle: Voluntary vs. Importer Obligations
Here’s the key point:
- A non-EU supplier can only submit voluntary PCNs through an EU-based legal entity.
- The voluntary PCN uses a voluntary UFI code, but this UFI cannot legally appear on the label because the non-EU company is not the duty holder.
So what does this mean in practice?
- Each importer is legally responsible for submitting their own PCN notification.
- Each importer also needs to generate their own UFI, which must be printed on the label.
The voluntary PCN in this case has just one purpose: it allows the non-EU supplier to protect the confidentiality of their full composition while still enabling importers to fulfill their obligations.
But Is There a Way to Use a Single UFI?
Yes — but only under specific conditions.
If all importers are using the same mixture composition, they can agree to use the same UFI. One importer generates the UFI, submits the PCN, and the others can use the same UFI in their own submissions. This way, the product can carry a single UFI on the label across the EU.
Another option is to simplify the supply chain:
- Work with a single importer, who then distributes the products further into the EU.
- That importer handles the PCN for all countries and ensures labeling is consistent.
Both options require coordination and trust, but they can save a lot of confusion and “messy” labeling.
What About an Authorized Representative Under GPSR?
The company also asked whether an EU Authorized Representative (AR) under the new General Product Safety Regulation (GPSR) can handle this role. The short answer is: no — at least not in the way they hoped.
An AR under GPSR is not the same as an entity responsible for chemical compliance. In this case, an AR cannot replace the importers’ duties for PCN and UFI labelling.
Takeaways for Non-EU Manufacturers
- Voluntary PCNs protect your formula but do not remove the legal duties from your EU importers.
- Your voluntary UFI cannot go on the label — only the UFI from an importer’s PCN submission can.
- Coordination is key: if you want a single UFI across all markets, importers must align and agree to use one generated UFI.
- Simplify where possible: if one importer can act as the main distributor, compliance and labeling become much easier.
If you’re a non-EU manufacturer facing similar challenges, don’t hesitate to reach out. We can help with voluntary PCNs, guide your importers through their PCN submissions, and make sure your products stay compliant while protecting confidentiality of your sensitive formulations.
Photo by pressfoto on freepik.com
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