The amendment of the CLP Regulation (EU Regulation (EC) No. 1272/2008 on classification, labelling and packaging of substances and mixtures) provides for a new identifier on products that contain hazardous mixtures. The first deadline for ensuring conformity expired on 1st January 2021. From that date onwards, product labels must contain a Unique Formula Identifier (UFI) code - a special 16-digit alphanumeric code - to declare the precise composition of the mixture.
This article provides an introduction to the new regulation and important information on the UFI code.
A summary of the CLP Regulation:
According to the CLP Regulation, manufacturers, importers and downstream users of products that contain hazardous mixtures must add a UFI code to their product labels.
The CLP Regulation is valid in the European Economic Area (EEA). This includes all 27 member states as well as Norway, Iceland, Liechtenstein and Switzerland – additional special regulations apply for the latter.
What is the UFI (Unique Formula Identifier)?
The UFI code helps to clearly identify a hazardous mixture, which enables poison centres to provide necessary first aid and advice sooner by establishing
a direct and unique link between the mixture that is put on the market and the associated safety information.
UFI codes are always encrypted forms of data, meaning that unauthorised third parties cannot obtain information on the composition of the mixture. Suppliers can therefore pass the code down the supply chain without any concerns.
This code is linked to a central database that contains safety information on every hazardous mixture. The opportunities provided by the variable online printing of the code in production lines increases the flexibility, versatility and reliability of production and the manufacturer’s processes.
When and where is a UFI code applied?
The CLP Regulation stipulates that the UFI code must be added to the product label and the safety data sheet. The UFI code must be printed in a clearly visible position on the label (e.g. near the barcode or the hazard pictograms). However, some products – especially in industrial plants – do not have a product label, in which case the UFI code must be indicated in the safety data sheet. In this case, directly labelling a product without a label is not mandatory, but can be implemented on a voluntary basis.
Please note, we are currently awaiting clarification as to whether the UFI code can also be added near the label if there is not enough space on the label itself.
If the product label contains a hazard pictogram representing a hazard to humans, the UFI must be stated on the label or in the safety data sheet.
It is important to note that the UFI code always relates to the mixture contained in the product. For example, the UFI code does not need to be changed if the brand name or product label changes.
The same is not true if the composition of the mixture is altered. In this case, a new UFI code is required and the changes need to be communicated to the relevant bodies. This is also necessary if the composition of a supplied mixture changes.
A hazardous mixture can also have multiple UFI codes. For example, if products A and B contain the same mixture, each “commercial product” needs to have its own UFI. The same UFI code cannot be valid for several mixtures.
Content and structure of the UFI code
The legislation provides clear specifications for the structure of the UFI code:
the 16-digit alphanumeric code consists of a formulation number, which defines the contents and the composition of the mixture, and the company’s value added tax (VAT) identification number. If no VAT identification number is available, a unique, notional VAT ID is created.
Central database for generating and managing the UFI code - the European Chemicals Agency (ECHA) is responsible for the central administration of the UFI codes. As an EU authority, the ECHA is responsible for the technical, scientific and administrative aspects of the registration, evaluation and approval of chemicals within the scope of the CLP Regulation. To generate the UFI code, the ECHA provides an online UFI generator, which can be accessed by manufacturers. The UFI codes must be communicated to the ECHA together with the assigned mixture to enable them to be officially registered. Any subsequent changes to the composition or concentration of the mixture must be communicated to the ECHA and the entire supply chain.
Deadlines specified in the CLP Regulation
The deadlines for complying with the requirements are as follows:
- 1stJanuary 2021: new hazardous mixtures that are supplied to consumers, e.g. drain cleaner, insect killer
- 1stJanuary 2021: new hazardous mixtures for commercial use. E.g. craftsperson’s businesses, businesses with no resales
- 1stJanuary 2024: new hazardous mixtures for industrial use, e.g. raw material suppliers
- 1stJanuary 2025: existing hazardous mixtures that are already registered and available on the market.
Applying the UFI code
Different technologies are available for applying the UFI code to your product depending on your production environment and the product to be labelled. For instance, the UFI code can be retrospectively printed onto an existing label/packaging design or integrated into the label production at an earlier stage. We have provided a summary of suitable coding technologies in our blog on implementing the EU CLP Regulation (German Language).
Please get in touch to discuss how Domino’s product range can assist in assigning your UFI codes.
“Please note: In case there is no space for the UFI-Code on the label itself it can be applied close to it on the product directly.
If the label displays one of the following hazardous signs the UFI needs to be printed on the label, close to it or in the safety data sheet.”