From Jan 1st 2021, a new label element will have to appear on the labels of all products classified for health or physical hazards. A 16-character code called the Unique Formula Identifier (UFI) will be mandatory on the labels of such products and importers and downstream users placing these products on the market will have to provide specific product information, including the UFI, to poison centres.
WHAT IS A UFI?
The Unique Formula Identifier (UFI) is a 16-character alphanumeric code that will be required on the label of products that contain a hazardous mixture.
In addition to having the UFI on your labels, you will also be required to provide information on your mixture, and associated products, to poison centres. Information will include such details as trade name, composition, colour, packaging, product category and toxicological information. The aim of the UFI is to establish an unambiguous link between the information you provide to the poison centre with the product you place on the market.
The condition for assigning a UFI, is that all products labelled and notified with the same UFI need to share the same mixture composition.
WHAT IS THE UFI USED FOR?
The Unique Formula Identifier, and the other information you provide, will be used by poison centres in the event of an emergency call. The UFI can be read directly from the label of a product to a poison centre operator, in addition to the trade name, to precisely identify the product involved in an incident. This will enable a better and more adequate medical response and a reduction of unnecessary over-treatment, which is often given just to be on the safe side.
HOW DO I CREATE A UFI?
To create a Unique Formula Identifier for your mixture, you need your company’s VAT number (or ‘company key’, in specific cases) and a mixture-specific formulation number. Entering these two numbers into ECHA’s UFI Generator online tool will provide you with your UFI code. The VAT number is a key element to ensure that your UFI is unique so that no overlap occurs between UFIs generated by different companies.
Most likely your company already uses internal formulation codes. If they are numerical only – between 0 and 268 435 255 – you can use them directly in the UFI Generator. In other cases, such as when they are alphanumeric or contain other characters, you will need to first assign new formulation numbers to your mixtures that follow the required format. It is essential that you do not re-use the same formulation number using the same VAT number when the mixtures have different compositions.
You can find the UFI Generator and the User Guide on ECHA’s Poison Centres website.
If you manage a large product portfolio, you may want to develop your own generator in your company’s IT system for more efficient bulk creation of UFIs. For this, you will need to consult the UFI developer’s manual.
UFI CODES – POST BREXIT
REACH registrations submitted by UK-based manufacturers, importers and representatives that were not completed by 31 December 2020 have been terminated.
Any transfer of registrations by a UK company not initiated before 31 December 2020, and accepted by the successor by 31 March 2021, will be revoked.
After 31st December, 2020:
- All pending UK submissions in REACH-IT will be terminated.
- No registration numbers will be issued to UK companies.
- Companies in the UK cannot perform any actions as duty holders in REACH-IT.
- All registrations held by or returned to UK companies will be revoked gradually in REACH-IT.
REACH stipulates that registrants must be established in the European Union.
WILL THE UFI KEEP YOUR BUSINESS INFORMATION CONFIDENTIAL?
The UFI respects the integrity of your confidential business information; it is not possible to decode information on the mixture composition from the UFI. Only poison centres will know which mixture composition corresponds to the UFI provided. In this way, the UFI protects your confidential business information.
CAN YOU USE ONE UFI FOR MULTIPLE PRODUCTS OR SEVERAL UFIS FOR ONE PRODUCT?
As long as the mixture composition in the product is the same, you can use the same UFI on the label of your products in all EEA countries, or you can use the same UFI on the label of the products within the same country, even if you market them under different trade names.
For data management or commercial reasons, you may choose to assign more than one UFI to the same mixture. In this case, each product would have its own UFI, even if it contains the same mixture.
DOES THE UFI ALWAYS HAVE TO BE INCLUDED ON THE LABEL?
The Unique Formula Identifier must be printed on or affixed to the label of all your products containing hazardous mixtures. In cases where products are not labelled – such as with certain products used on industrial sites – the UFI can be indicated in the safety data sheet.
WHAT ARE THE UFI CODE SPECIFICATIONS FOR LABELS?
The acronym ‘UFI’ (the same in all EU languages and alphabets, and not to be translated) must be in capital letters and be followed by a 16-character alphanumeric code. The code is divided into four blocks, each separated by a hyphen. While no specific requirements have been set, for instance, for font type or size, the UFI has to be clearly visible and legible on the label of the product. Given the variation in label sizes, and other labelling requirements competing for label space, the UFI should be positioned so that it is easy to locate (e.g. near the barcode or hazard pictograms). In essence, you must determine how the UFI must be printed or affixed in the most effective manner to assist with its communication to poison centres.
NEXT STEPS?
The new requirements will begin in January 2021. Your company will be obligated to notify the Unique Formula Identifier by 1st January 2021 for mixtures intended for consumer and professional use, and mixtures for industrial use only by 1st January 2024.
Importers and downstream users placing hazardous mixtures on the market in the EU should start preparing now for the implementation of the new submission procedure and for the use of the UFI on product labels.
Companies need to be ready with the UFIs on labels before their deadline to submit the product information to the poison centres. In practice, this means that the generation of UFIs and the printing of appropriate product labels should be carefully planned into your company’s schedule and can be executed in advance of the relevant submission deadlines.
The UFI GENERATOR TOOL and support to generate the UFI are available on ECHA’s Poison Centres website, along with a UFI DEVELOPERS MANUAL to guide you through this process.
Hibiscus Plc has been providing regulatory advice and labelling solutions for dangerous goods retailers and wholesale chemical suppliers for nearly 40 years.
VISIT OUR WEBSITE FOR MORE INFORMATION ON PRODUCT LABELS AND LABELLING FOR DANGEROUS GOODS.
TO UPDATE YOUR LABELS, CALL OUR SALES OFFICE ON 0113 242 4272