Article 45 of Regulation (EC) No. 1272/2008 (CLP) establishes that the entity responsible for placing a hazardous mixture on the market due to health or physico-chemical effects must notify the relevant information to enable preventive and remedial measures, particularly in cases of emergency health responses (e.g., incidents involving workers or consumers during the use of the hazardous product). The notification is harmonized for the EU market, with ECHA adopting a unified system that allows all notifying entities to transmit the required information in a single format through the PCN (Poison Centres Notification) portal.
The entities required to submit PCN notifications are Importers and Downstream Users placing hazardous mixtures on the market in an EU country due to health or physico-chemical effects. Within the category of Downstream Users directly obligated to notify are Formulators and Repackagers, who place the original manufacturer’s mixtures on the market in different formats. Distributors, who do not have a direct obligation to notify, such as Retailers of the original product or Rebranders commissioning the production of mixtures to third parties and placing their brand on the packaging, must still ensure that the information regarding the hazardous mixture they place on the EU country market has been fully transmitted through the harmonized notification. This means that if suppliers upstream fail to submit notifications covering all information related to the distributed mixtures, these entities must notify independently.
A key element of harmonized notification is the adoption of the UFI code, the Unique Formula Identifier, a 16-character alphanumeric code that establishes an unequivocal link between the information submitted with the mixture notification and the specific product placed on the market.
The UFI must be displayed on the product label, or on the inner or outer packaging. For unpackaged mixtures, the UFI must be included in the Safety Data Sheet or in a copy of the label elements.
Distributors must ensure that only CLP-compliant mixtures are placed on the market, guaranteeing that all product identifiers, particularly the trade name/brand and UFI, are covered by a notification.
We can support you through all stages of the Notification process for your hazardous mixtures, starting with structured training tailored to your specific needs.