We get this question very often, so let's take a few minutes today and see what the law says and requires of you about it. Let's start with the basics.
What is a UFI code?
UFI or Unique Formula Identifier is a 16-digit code used to label hazardous mixtures classified as hazardous for health or with physical hazards. It is a mandatory part of the chemical legislation, which entered into force on 1 January 2021 and is intended to protect users of chemicals and take appropriate action in the event of poisoning.
The UFI code creates an unambiguous link between the mixture placed on the EU market and the information available to emergency poison centres. Each UFI code refers to one – and only one – specific composition of the mixture.
Is it mandatory to indicate the UFI code on the packaging?
The UFI code is generally mandatory on the label of any packaged mixture classified as hazardous (except for the exceptions mentioned above) placed on the market in the European Economic Area (EEA).
This means:
- The UFI must be clearly indicated on the inner packaging of the product (if there is not enough space, then it can be on the outer packaging)
- The code must be readable and durable
The UFI shall be stated together with the other elements of CLP labelling. This requirement applies generally to all hazardous mixtures intended for consumer, professional and industrial use.
UFI in the Safety Data Sheet – when is it mandatory?
Here, the answer is a bit more complex. In general, the UFI code is not mandatory in safety data sheets for hazardous mixtures (in accordance with Regulation (EC) No 1272/2008, Annex VIII, Part A, Chapter 5).
However, there is an important exception. The UFI code is mandatory in the safety data sheet (or in a copy of the label elements) for hazardous mixtures sold in bulk.
Typical examples of such mixtures are:
- Wet concrete delivered in a "pear" truck.
- Other chemicals delivered in tanks or bulk goods.
- Mixtures not prepackaged for the end user.
In such cases, where the product is not packaged and therefore does not have a label, the UFI code in the safety data sheet (or in a copy of the label elements) is mandatory, as this is the only way to convey this critical information to the user.
In fact, in practice, we notice that almost all safety data sheets also contain UFI codes. So it makes sense to look ...
Where to provide the UFI code in the safety data sheet?
If you choose to include the UFI code in the safety data sheet (voluntary) or if it is mandatory (bulk mixtures), the UFI code must always be indicated in section 1.1 of the safety data sheet. There are no other options or exceptions to this.
As I have already indicated, the voluntary listing of UFI in SDS is a good practice that should be taken into account.
Although the UFI is not mandatory in the safety data sheet in most cases, many companies include this information voluntarily. Why?
- Provides comprehensive information to supply chain partners
- Facilitates traceability and product management
- Prevents confusion for users looking for a UFI code
- Enables better communication in case of emergencies
Before concluding, let's look at another essential element that is connected to the UFI code. It's a PCN.
Link between UFI and PCN
It is important to understand that the UFI code is inseparably linked to the PCN (Poison Centre Notification) notification. When you submit a PCN for your hazardous mixture, a specific UFI code is linked to the exact chemical composition of that mixture in poison center databases.
This means that you can only use a specific UFI code for products with the same composition (or with minor tolerances allowed). If the composition of the mixture changes (beyond the minor tolerances), a new UFI code and a new PCN are required.
UFI codes and PCNs have become standard in the chemical industry, but they can still cause confusion. If you have any further questions about when and where to provide the UFI code, or if you need help with notifications, you can contact me.
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