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Step by Step Interpretation of New GHS Marker Elements for EU Hazardous Mixtures -- UFI (Step 2)

Posted Date:2023/2/3 3

Starting from January 1, 2020, the Unique Recipe Identifier (UFI) is a new marking element that needs to be added to the existing hazardous mixture CLP/GHS label for consumer use.By 2025, UFI will become a mandatory requirement on the labels of all mixtures classified as health or physical hazards. Note: The first compliance date for hazardous mixtures for consumer use has been postponed from 1 January 2020 to 1 January 2021.

Not only does UFI require labelling, but it is also required in the European Union's Poison Centre Notification (PCN). Importers and downstream users are directly responsible for submitting a Poison Centre Notice (PCN) to the ECHA when placing hazardous mixtures (classified as hazardous substances based on their health or physical effects) on the EU market.

Therefore, I will make a detailed interpretation in seven steps, including the scope of UFI obligations, product portfolio, how to generate UFI and how to submit data.

Step 2: Standard information requirements

The harmonisation of information requirements means that existing national requirements have been replaced by the same set of information requirements and the same data submission format (Poison Centre Notification (PCN) format) throughout the EU.

Some information requirements may be new compared to previous ones. You may need to generate new information or adapt existing information to PCN format.

The Unique Formula Identifier (UFI) is a new submission requirement and a new tag element that will be detailed in Step four (Step four of the following article). Example of UFI in correct format: YV9K-3J9A-G209-C2T7. UFI establishes a clear link between the mixture information you provide through the notification and the corresponding product placed on the market, which helps ensure that an appropriate emergency health response is quickly identified in the event of an accident.

The full chemical composition (all components) of the mixture is required. This means that you must indicate the exact concentration or concentration range of hazardous and non-hazardous ingredients. This is not only the information normally provided in the Safety Data Sheet (SDS), but also some hidden ingredients and other health hazards not found in GHS.

Toxicological information on the mixture is required. This information will need to be provided as free text and can usually be found in section 11 of the security data sheet (11. 11.Toxicological information).

Product categories must be assigned according to the main intended use of the product in accordance with the European Product Classification System (EuPCS), for example, dishwashing detergent, adhesives, decorative coatings.

All submissions must also contain information identifying the submitter, product information (e.g., trade name, packaging, color) and whether the mixture has consumer, professional or industrial uses. In addition, information about the classification and labeling of mixtures under CLP regulations is required.