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New legislation introduced for hazardous product packaging - Creating your UFI codes
Published: 23 April 2019
Changes in EU legislation relating to packaging of products containing hazardous properties, including most household cleaning products and paint, as well as adhesives, coatings and primers, will soon be coming into force. All packaging must contain a unique formula identifier (UFI), a 16-character code which will be used by poison centres for emergency health response purposes in case of incidents involving the product. What isn’t widely acknowledged is how quickly manufacturers and re-packers need to act to meet the requirements.
Get ‘UFI’ ready
Those placing such products on the market will have to provide specific product information, including the UFI, to poison centres. If you place the product on the market under your brand, you will need to create your own individual UFI – Apollo cannot do this for you, but we can support you with adding this to your label.
Your company will be obligated to have notified poison centres of the UFI and have this on the product label by the following deadlines:
- 1 January 2021 for products intended for consumer use (this has been postponed from the original January 2020 date)
- 1 January 2021 for products intended for professional use
- 1 January 2024 for products intended for industrial use only
Buy yourself some time
Existing products already on the market can benefit from a transitional period until 1 January 2025, if your product data and Safety Data Sheets (SDS) are registered with the applicable poison centre for each EU member state your product is sold into by January 2020 – otherwise the above deadlines will still apply. Find out how to do this here.
New products going to market will need to adhere to the original deadlines above.
Creating your UFI number
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.
View our step-by-step guide to creating a UFI here.
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.
By getting your products registered, and taking advantage of the extended transitional period, the creation of UFIs and amending of labels can be scheduled into ongoing planning programmes.
Can you 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 you 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.
For more information, please refer to the ECHA guidelines, or contact your Account Manager or Apollo’s Compliance department.
WHAT’S NEXT: Adding your UFI to product packaging
Whilst no specific requirements have been communicated for adding your UFI, for instance the positioning or font size, the UFI has to be clearly visible and legible on the label of the product. Find out more information here.
If you require any further information in the meantime, please contact your Account Manager or Apollo's Compliance department.
An example label showing the UFI positioned under the hazard symbols.