Old Products Without UFI: Can They Still Be Sold in Slovenia?

This is one of those topics where theory and practice don't quite go hand in hand.

The question usually goes like this:

»The products were placed on the market before January 1, 2025. They were registered in ISK. They don't have a UFI. Can we still sell them?«

If we look at the legislation, my answer is: yes, in certain cases. Let me explain. If the products were legally placed on the market before the obligation came into effect and were correctly registered in ISK, they are theoretically allowed to be sold off.

Now, the reality.

How will you prove during an inspection that this exact can, this exact batch, this exact packaging
was indeed placed on the market before a certain date?

In practice, this means proving with delivery notes, recording batches, reconstructing timelines, and very little patience on the other side of the table.

From our experience, we know the following: If the products are still in the warehouse and you're just putting them on the shelves, UFI almost always becomes necessary, regardless of when they were manufactured.

The law allows for the possibility. The market, however, does not.

Practical Lesson:

What is legally possible is not always practically feasible. If you want peace of mind, having a UFI on old products is often a smaller cost than lengthy explanations and penalties.

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

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