The road to European product notification, part 2 – The unique formula identifier UFI

The unique formula identifier UFI is introduced along with the European product notification. The UFI is used for the identification of mixtures. At this year’s Workshop on the implementation of Annex VIII to CLP, UFIs were one of the big topics, especially during the rounds of questions. The explanations provided by the speakers helped clarify a number of issues.

UFI generator: How do I assign the new number?

My colleagues and I went to look a the UFI generator as soon as it became available. But the result raised some further questions.

The generator uses the company VAT number with the option of entering additional formulation numbers. What happens now is that a UFI is generated for each formulation number that is entered here. We were surprised that the numbers were not random. If the same VAT number and the same formulation number is entered, this always produces the same UFI. As the numbers are supposed to be unique, we would have expected random, unique numbers. However, the approach here is a different one, as was demonstrated in the workshop:

The in-house article numbers are to be converted to UFIs via several steps:

• The article numbers are to be converted into pure numerical form.
• These numeric article numbers are then to be used as formulation numbers in the UFI generator.
• Therefore, the generated UFI is always the same for every formulation number.

This explains the procedure, though the conversion isn’t always as straight forward. The UFI is subject to fixed rules. If the formulation changes too much (CLP, Annex VIII, Part B, 4.1), a new UFI must be assigned. If the company has already assigned several UFIs for a mixture, all of these will need to be generated again. This is where the UFI application can differ from real life article number allocation.

The unique formula identifier under discussion

The workshop’s rounds of questions generated some interesting considerations in terms of the UFI:

If a supplier wants to launch a manufacturer’s product under their own name, they have the following choices:

The unique formula identifier UFI of the manufacturer can appear on the hazardous substance label. This would require no further action but is not what everyone wants. If you want an untraceable UFI, you will need to create your own – but this requires your own new product notification too!

If the supplier of a external component modifies a UFI, the notification concerning the company product must also be adapted using the new UFI.

As mentioned before, notable modifications to a mixture may result in a new UFI requirement. Because the UFI also appears on the identification label, this automatically translates into: New UFI – new identification label.

However, the allocation and maintenance of UFIs has not been finalised yet. There will be a workability study to evaluate the practicality of the entire notification process for different industry sectors before the European notification comes into effect.

In the next part (Part 3), I will discuss how specific the information on the formulation needs to be for the new notification, also comparing this to the BfR product notification that is currently in use in Germany.

Sources: Workshop on implementation of Annex VIII to CLP

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Annex VIII to the CLP Regulation (EU 2017/542)