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Trace One
UFI-PCN: Article 45 and Annex VIII of the CLP
According to Article 45 of Regulation 1272/2008 (CLP), importers and downstream users placing hazardous mixtures on the market shall provide relevant information to appointed bodies for emergency health response purposes. Annex VIII of the same regulation defines the content and procedure for harmonized submission across all Member States, as well as the compliance dates for harmonized submission, which vary depending on the intended use of the product subject to notification requirements. Specifically, January 1st, 2021, marked the compliance date for mixtures intended for consumer and professional use, while January 1st, 2024, was the compliance date for mixtures intended for industrial use. Regardless of the intended use of the products, in case of mixtures notified according to Article 45 before the appropriate compliance date, there is no obligation to comply with Annex VIII until 1st January 2025, except in cases where updated information is needed.
UFI-PCN: end of transition period
The 1st January 2025 marks the end of the transition period for poison centre notifications (PCN). The transition period allowed companies to continue placing their hazardous mixtures on the market under non-harmonised national requirements. Starting on January 1st, 2025, all companies will have to adopt the harmonised format for their PCN notifications. This applies to companies whose mixtures were previously notified according to national guidelines. Therefore, if companies intend to continue placing such mixtures on the market after this date, they will have to submit a new notification according to Annex VIII and include the unique formula identifier (UFI) on the label.
PCN inspections
ECHA’s Enforcement Forum prepared a project to check whether suppliers have notified hazardous chemical mixtures to poison control centres.
The aim of the inspections is to ensure that chemical suppliers comply with their obligation to notify the national authorities of information on hazardous mixtures in order to protect human health. National authorities make this information available to poison control centres, which can then provide appropriate advice to citizens or medical personnel in the event of an emergency. For this reason, it is essential that poison centres have accurate data on hazardous mixtures so that emergency response is informed and appropriate.
Inspectors will check that the notification has been submitted and will verify the labels of the mixtures and, if necessary, the safety data sheets. Inspections in this project will begin in January 2025 and continue for six months, with the project report being published at the end of 2025.
Trace One is paying close attention to the development of the regulatory situation and will keep you updated on any news on this issue.
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