Poison Centre Notification
The last deadline for the Poison Centre Notification (PCN) expired on 1 January 2024! Apart from a few exceptions (e.g. grandfathering), all physically and/or health hazardous mixtures must now be notified in order to be sold on the European market.
Non-notified products without a unique formula identifier (UFI) can now be quickly identified by any market participant. This can have both legal and economic consequences.
Together with us, you have the challenges of updates and communication in the supply chain under control!
This makes us your ideal partner
"In my experience, there are still companies that are unsure whether they are affected by the product notification and how often it needs to be updated. We also see communication issues in the supply chain time and time again. My team and I help you to achieve clarity in all areas so that you can act efficiently and avoid extensive coordination loops in your day-to-day business."
Anna-Lena Quitzau | Expert for Poison Centre Notification
This is also confirmed by our customers
"We at einzA Farben and einzA Lackfabrik have been working successfully with UMCO for many years. Over time, this cooperation has developed into an indispensable factor with regard to hazardous substances, biocides and dangerous goods. A joint data exchange via import tables has been established so that we can react quickly to recipe changes, new raw material plants or amended raw material data sheets. This means that our labels, safety data sheets and transport documents are always up to date. The UHCS adapter allows us to view our data at any time and obtain a detailed overview of our products through targeted queries. The legal requirements are becoming more complex and it is becoming increasingly difficult to keep an eye on everything. That's why the direct professional exchange with UMCO is so important."
Petra Peters, Laboratory Management | einzA Farben GmbH Co. KG
Questions & answers about the PCN message
The UFI (Unique Form Identifier) is a new labelling element from the CLP Regulation that has been on the first products since 1 January 2021. This first deadline applied to hazardous mixtures used privately and commercially. Industrially used mixtures followed on 1 January 2024 and on 1 January 2025 the grandfathering of products previously notified under the "old" procedures will expire. From this date, the UFI will be found as a 16-digit, alphanumeric formulation identifier on all products that fall under the CLP Regulation and are classified as health or physical hazards.
The UFI is intended to facilitate the identification of products for emergency medical advice by poison information centres, as every second can count.
With the entry into force of Annex VIII of the CLP Regulation, the existing national notifications were replaced. A standardised, electronic format for data transmission was implemented. Since 2021, all product notification information transmitted to the ECHA or the national poison information centres must comply with the XML format defined by the ECHA.
Although a lot of product information can already be taken from the safety data sheet (SDS), the data required as part of the product notification is far more detailed. In particular, the complete compositions of the mixtures are important mandatory information. The following information, among others, must be included in the notification:
- Reporting region
- 16-digit UFI
- CLP classification and labelling
- Toxicological information
- Colour, physical state, pH value
- Packaging type and size
- Product category (EuPCS)
- Use (consumer, trade, industry)
- Components of a mixture with exact value or concentration range according to Annex VIII CLP
- Substances classified as hazardous to health or physically hazardous from ≥ 0.1 % (if "identified" < 0.1 %!)
- Environmentally hazardous and non-classified components from ≥ 1%
Article 45 imposes an obligation on ECHA and national authorities to ensure that the information is treated confidentially and used only to provide information on preventive and curative health measures or to identify improved risk management measures. Use for other purposes is not permitted. The UFI does not allow any conclusions to be drawn about the composition. This is only possible for poison information centres that have the relevant data on the ingredients.
The complete composition must be stated in the product notification. This also includes non-hazardous components, meaning that the information from raw material data sheets is not sufficient. In order to still be able to fulfil the notification obligation without knowing the exact composition of raw materials, there is the concept of "mixture in mixture" (MiM). It is possible to specify a raw material as a component of one's own formulation without knowing the complete composition of the raw material. The UFI of the raw material alone gives the poison information centres knowledge of all the ingredients it contains.
All information relevant for emergency medical advice must be up to date at all times. Changes must therefore be reported to ECHA immediately. As the UFI is a formulation-related identifier, it is only necessary to generate a new UFI if the composition of the mixture changes. Due to the complexity of many products in terms of their formulation, changes to the formulation of the raw materials used or changes in raw material suppliers can have a direct impact on your own product notifications and those of the entire supply chain.
Even if retailers only purchase products and resell them unchanged, they could be affected by the notification obligation. This is because it must be ensured that the notifiable product is registered in the EU country in which it is placed on the market. For example, if the intention is to sell a commercial product in France, while the supplier has only registered in Germany, the retailer must carry out their own notification. Communication with the supplier and along the supply chain is extremely important here. In addition, activities such as refilling/repackaging or renaming the product generally mean that distributors are also subject to the obligations of harmonised product notification.
