UFI Codes and Product Packaging

All packaging must contain a UFI number, a 16-character code which will be used by poison centres for emergency health response purposes in case of incidents involving the product. Here we explain the legislation and what you need to do.

As a result of a change in EU legislation, article 45 of CLP, there are some essential changes coming to the packaging of products containing hazardous properties sold into the EU (including Southern Ireland) and Northern Ireland. All packaging must contain a UFI number, a 16-character code which will be used by poison centres for emergency health response purposes in case of incidents involving the product.

The changes will apply to goods containing hazardous properties, including most household cleaning products and paint, as well as adhesives, coatings and primers.

If you supply product into England, Wales and Scotland only, you do not require a UFI code.

What is a UFI code?

A new label element will need to appear on product labels from 2021 – a 16-character alphanumeric code called the unique formula identifier (UFI). By 2025, the UFI will be mandatory on the label of all products that contain a hazardous mixture, i.e. classified for health or physical hazards, sold into the EU (including Southern Ireland) and Northern Ireland.

Those placing such products on the market will have to provide specific product information, including the UFI, to poison centres. If you place our product on the market under your brand, you will need to register your product and create your own individual UFI – Apollo cannot do this for you.

When are UFI changes required?

Your company will be obligated to have notified poison centres of the UFI and other product information by the following deadlines, if you have not already submitted your product details and MSDS to applicable poison centres to benefit from the extended deadline:

• 1 January 2021 for products intended for consumer use
• 1 January 2021 for products intended for professional use
• 1 January 2024 for products intended for industrial use only

You need to be ready with your UFI on the label before your deadline to submit this product information to the applicable poison centres. For new products, you must submit the required information before you place the mixture on the market.

How to create a UFI

Simply enter your company’s VAT number and a mixture-specific formulation number into the ECHA’s UFI Generator online tool to get your UFI code.

If you currently use internal formulation codes that are not purely numerical, you may need to give new numbers to 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.

Can I use one UFI for multiple products, or several UFIs for one product?

As long as the mixture composition is the same you can use the same UFI on the label of your products in all countries, and even if you market them under different trade names. For commercial reasons, you may choose to give more than one UFI to the same mixture. These products would therefore have individual UFI codes, even though they contain the same mixture.

When do I need a new UFI code?

As long as the mixture composition remains the same, the UFI code can remain the same, even if other changes to the product occur, such as new packaging or a new product name. A new UFI only needs to be created and added to the label when a change in the mixture composition occurs. Apollo will notify you far in advance if any changes to mixture compositions are planned.

What are the rules for adding UFI codes to products?

Once you have created your 16-character alphanumeric UFI codes, these must be printed on to the label of all your products containing hazardous mixtures in time for the appropriate deadlines above.

The acronym ‘UFI’ must be in capital letters and be followed by a 16-character alphanumeric code. While no specific requirements have been set, such as for font type or size, the UFI has to be clearly visible and legible on the label of the product.

Given the wide variation in label sizes, and the other label elements competing for space, the UFI should be positioned so that it can be easily located, for example near the hazard pictograms. You must determine how the UFI should be printed in the most effective manner to ensure it is clearly visible. An example of a label clearly showing the UFI code is below:

Standard H&S labels printed at Apollo, with your branding: On standard branded health and safety labels printed at Apollo (known as E1 labels), we can add the UFI code to the label. As you are placing the product on the market under your brand, you will need to create your specific UFI code for each product and notify the applicable poison centres yourselves. You will then need to provide us with your specific UFI for the product, so we can add this to the label. This is simple for us to add on with the software that automatically creates the labels and can be actioned as soon as you have created your UFI code.

Fully-branded labels: Fully-branded labels (known as E2 labels at Apollo) that incorporate health and safety, will need to be amended to add the UFI code, following earlier guidelines. The updated artwork will need to be sent to us in plenty of time before the applicable deadlines or product launch. This ensures we can check the label and order them in time.

If Apollo have designed your label for you, you will need to provide us with your UFI code so we can get the artwork amended.

Registering UFI with poison centres

Once your UFI code is ready on your labels, the final stage is to submit a poison centre notification (PCN) dossier to the ECHA submission portal. The UFI on the label of the product should coincide with the PCN submission. This will involve supplying product information including the UFI and formulation composition details. You may not have the full composition details of the product. In this case, you can put our UFI for the product in the composition details section. Please contact Apollo so we can provide you with our UFI code.

Further information on how to create a dossier can be found here.

For more information, please refer to the ECHA guidelines, or contact your Account Manager or Apollo’s Compliance department.