My product is only hazardous to the environment – do I really need a UFI?

This is one of the most common misconceptions about UFIs. And it's very understandable.

Many companies see the environmental hazard symbol and automatically conclude: "This is dangerous, so I need a UFI."

But UFI has its own criteria.

First criterion: is it a mixture?

UFI applies exclusively to mixtures. Substances do not require a UFI.

Second criterion: classification with H2XX or H3XX

If a mixture is classified only as environmentally hazardous (H4XX), a UFI is not mandatory.
However, once an H2xx or H3xx statement appears (indicating health or physical hazard), the situation changes.

At that point:

• UFI becomes a mandatory element on the label,
• PCN notification is required,
• Products without a UFI and PCN cannot be marketed.

Looking at it more closely, it's important to emphasize that not every classification with an H2xx statement automatically triggers a PCN requirement.

Exceptions include:

• gases under pressure (H280, H281) and
• explosives (H200, H201, H202, H203, H204, H205).

In the event of an accident with such products, a UFI does not contribute to handling the case, as these typically involve immediate and severe physical injuries, where the doctor does not need information about the chemical composition of the mixture.

Simply put, it's enough to remember that UFI and PCN should be managed in cases of H2XX or H3XX classification.

Where do things often go wrong in practice?

Often, the determination of whether a product is hazardously classified and requires a UFI and PCN is based solely on whether the packaging has pictograms. However, not every H-statement requires a pictogram. And some H statements for environmental hazards H4XX do have prescribed pictograms.

Therefore, it's always necessary to check the safety data sheet, in section 2, to see which H-statements are assigned to the product.

Practical lesson:

For determining the need for UFI and PCN, do not look at pictograms. Look at the classification in section 2 of the safety data sheet.

If you need help managing the challenges of chemical legislation, feel free to contact me at urska.poje@bens-consulting.eu.

P.S.: You can also watch my lecture on the most common questions and issues related to UFIs and PCNs at this link. Or check out the presentation I prepared for this purpose.