The revision of the EU CLP Regulation (EU Regulation (EC) No. 1272/2008 concerning the classification, labelling, and packaging of substances and mixtures) introduces a fresh identifier for products containing hazardous mixtures. The initial deadline for compliance lapsed on 1st January 2021. Henceforth, product labels are required to incorporate a Unique Formula Identifier (UFI) code – a distinct 16-digit alphanumeric code – to specify the exact composition of the mixture. This article serves as an introduction to the updated regulation and offers crucial details on the UFI code.
A summary of the CLP Regulation:
As per the CLP Regulation, producers, importers, and downstream users of items containing dangerous mixtures are required to include a UFI code on their product labels.
The CLP Regulation is applicable within the European Economic Area (EEA), encompassing all 27 member states, along with Norway, Iceland, Liechtenstein, and Switzerland. Special regulations are applicable to the latter.
What is the UFI (Unique Formula Identifier)?
The UFI code serves the purpose of clearly identifying a hazardous mixture, allowing poison centres to offer prompt first aid and advice by establishing a direct and unique link between the marketed mixture and its associated safety information.
UFI codes always consist of encrypted data, ensuring that unauthorized third parties cannot access information regarding the mixture’s composition. Suppliers can, therefore, transmit the code through the supply chain without any concerns.
This code is associated with a central database containing safety details for each hazardous mixture. The ability to variably print the code online during production enhances the flexibility, adaptability, and reliability of both production and the manufacturer’s processes.
When and where is a UFI code applied?
According to the CLP Regulation, the UFI code must be included on both the product label and the safety data sheet. The UFI code should be prominently printed on the label, such as near the barcode or hazard pictograms. However, certain products, particularly those in industrial settings, may lack a product label. In such cases, the UFI code should be specified in the safety data sheet. While directly labelling a product without a label is not obligatory, it can be voluntarily implemented.
Please note that we are currently awaiting clarification regarding the possibility of adding the UFI code near the label if there is insufficient space on the label itself.
If the product label features a hazard pictogram indicating a risk to humans, the UFI must be indicated on the label or in the safety data sheet.
It’s crucial to understand that the UFI code consistently pertains to the mixture within the product. For instance, there’s no need to change the UFI code if the brand name or product label changes.
However, if the composition of the mixture is modified, a new UFI code is necessary, and these alterations must be communicated to the relevant authorities. This is also applicable if the composition of a supplied mixture undergoes changes.
A hazardous mixture may have multiple UFI codes. For instance, if products A and B contain the same mixture, each “commercial product” must have its own UFI. The same UFI code cannot be valid for several mixtures.
Content and structure of the UFI code
The legislation outlines specific criteria for the structure of the UFI code: the 16-digit alphanumeric code comprises a formulation number, defining the contents and composition of the mixture, and the company’s value-added tax (VAT) identification number. If there is no available VAT identification number, a unique hypothetical VAT ID is generated.
The European Chemicals Agency (ECHA) oversees the central database for generating and managing UFI codes. As an EU authority, the ECHA is responsible for the technical, scientific, and administrative aspects of registering, evaluating, and approving chemicals under the CLP Regulation. To generate the UFI code, the ECHA offers an online UFI generator accessible to manufacturers. Manufacturers must communicate UFI codes to the ECHA along with the assigned mixture for official registration. Any subsequent changes to the mixture’s composition or concentration must be reported to the ECHA and the entire supply chain.
Deadlines specified in the CLP Regulation
The deadlines for meeting the stipulated requirements are as follows:
1st January 2021: Newly supplied hazardous mixtures for consumers, such as drain cleaner or insect killer. 1st January 2021: Newly supplied hazardous mixtures for commercial use, for instance, businesses of craftspeople or those with no resales. 1st January 2024: Newly supplied hazardous mixtures for industrial use, like raw material suppliers. 1st January 2025: Existing hazardous mixtures already registered and available on the market.
Applying the UFI code
Various technologies are accessible for incorporating the UFI code onto your product, contingent on your production environment and the nature of the product to be labeled. For example, the UFI code can be added later to an existing label or packaging design, or it can be integrated into the label production process at an earlier stage.
Feel free to contact us to explore how Domino’s product range can aid in assigning your UFI codes.
“Please be aware: If there is insufficient space on the label itself for the UFI code, it can be applied in close proximity directly to the product.
If the label features any of the specified hazardous signs, the UFI must be printed on the label, in close proximity, or in the safety data sheet.”