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Unique Formula Identifier (UFI) Codes - Your Label Requirements
Published: 01 May 2019
Changes in EU legislation relating to packaging of products containing hazardous properties are soon coming into force. From as early as January 2020 (for consumer products), these products must display a unique formula identifier (UFI). Products intended for professional use must feature the UFI from January 2021 and products for industrial use from January 2024. By January 2025, the UFI will be mandatory.
Existing products already on the market can benefit from a transitional period until 1 January 2025, if your product data and Safety Data Sheets (SDS) are registered with the applicable poison centre for each EU member state your product is sold into by January 2020 - otherwise the above deadlines will still apply. This will give more time to create your UFI and add it to your labels. Find out how to do this here.
Once you have created your 16-character alphanumeric UFI codes [find out how here], these must be printed on to the label of all of your products containing hazardous mixtures in time for the appropriate deadlines above.
What are the rules for adding UFI codes to products?
The acronym ‘UFI’ must be in capital letters and be followed by a 16-character alphanumeric code. While no specific requirements have been set, such as for font type or size, the UFI has to be clearly visible and legible on the label of the product.
Given the wide variation in label sizes, and the other label elements competing for space, the UFI should be positioned so that it can be easily located , for example near the hazard pictograms. You must determine how the UFI should be printed in the most effective manner to ensure it is clearly visible. An example of a label clearly showing the UFI code is below:
See below for what you need to do for Apollo’s different label types:
Apollo branded products
You will not need to do anything if you sell these products into the UK. Apollo have provided all of our own Apollo Safety Data Sheets (SDS) to the NPIS, the UKs poison centre – this means no UFI is required on Apollo branded products until 2025. In line with this date, the UFI codes will be automatically added to our labels.
Standard H&S labels printed at Apollo, with your branding
On standard branded health and safety labels printed at Apollo (known as E1 labels), we can add the UFI code to the label as shown below. As you are placing the product on the market under your brand, you will need to create your specific UFI code for each product and notify the applicable poison centres yourselves. You will then need to provide us with your specific UFI for the product, so we can add this to the label. This is simple for us to add on with the software that automatically creates the labels, and can be actioned as soon as you have created your UFI code.
An example of a standard customer branded H&S label printed at Apollo
Fully-branded labels (known as E2 labels at Apollo) that incorporate health and safety, will require more planning. The label artwork will need to be amended to add the UFI code, following earlier guidelines. The updated artwork will need to be sent to us in plenty of time before the applicable deadlines. This ensures we can check the label and order them in time.
If Apollo have designed your label for you, you will need to provide us with your UFI code so we can get the artwork amended.
Fully-branded labels will require careful planning as we will likely have current stock of labels without the UFI code on. Please speak with your Account Manager about current label stocks or if you have any other queries.
Registering UFI with poison centres
Once your UFI code is ready on your labels, the final stage is to submit a poison centre notification (PCN) dossier to the ECHA submission portal. This will involve supplying product information including the UFI and formulation composition details. You may not have the full composition details of the product. In this case, you can put our UFI for the product in the composition details section. Please contact Apollo if you plan not to use the extension period so we can provide you with our UFI code. The portal for uploading product information went live on 24th April 2019, further information on how to create a dossier can be found here: https://poisoncentres.echa.europa.eu/echa-submission-portal.
If you require any further information, please contact your Account Manager or Apollo's Compliance department.