PCN notifications and UFI codes are not “just another bureaucratic checkbox.” Everything starts with the composition of your product. Once you understand this connection, it becomes obvious why some products require multiple notifications or several UFI codes—while others don’t require any additional steps at all.
Many companies run into the same roadblocks when starting with PCN: How much of the composition do we even need to disclose? When do we need a new UFI code? And is one notification enough for a product—or do we need several?
If you find yourself nodding along, you’re in the right place.
Below, I walk you through the most common questions and give you a simple logic you can use to quickly determine—for any product—which PCN notification you need and how many UFI codes you should have.
Let’s start.
1. Do we need to disclose the full composition of the product to ensure compliance with EU PCN notification requirements?
Disclosing the full composition is highly recommended, but it’s not mandatory for a successful PCN notification.
The minimum required disclosure is 90% of the product’s composition.
If you cannot obtain or do not want to disclose 90% of the composition, you can submit a MiM (mixture in mixture) notification instead.
The key purpose of PCN notifications is to ensure that the EU has the necessary hazard information in case of an emergency threatening human health or the environment. With the ECHA Submission Portal, this information becomes easily accessible to first responders and medical personnel.
You can read more about the data required for a successful PCN notification here.
2. Do we need a PCN notification for every country?
Yes. You need a PCN notification for every EU country where your product will be placed on the market.
This means that a PCN notification created for Slovenia applies only in Slovenia—not across the entire EU.
It’s also worth mentioning that four EU countries charge additional national fees for placing products on their market: Ireland, Hungary, Belgium, and Italy.
Each has its own rules and pricing.
3. Do we need different UFI codes for different countries?
No. You create one UFI code per product, and you can use it across multiple markets.
However, you can assign multiple UFI codes to the same product if you want to—this is entirely your choice.
A common example is a cleaner sold in several fragrances while keeping the same composition. In this case, you can either:
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create one UFI code for all fragrances, or
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create multiple UFI codes and assign a separate one to each fragrance.
If all products share the same UFI code, it signals that their composition is identical.
On the other hand, using different UFI codes on the labels can hide the fact that the composition is the same across all versions.
4. Does an English safety data sheet cover the entire EU?
No. English covers many countries, but not all. If you’re wondering which languages your safety data sheets must be in, then this article is definitely for you.
If you have any additional questions, feel free to reach out at spela.hudobivnik@bens-consulting.eu—I’m here to help.
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