European Product Change Notification – frequently asked questions on UFI positioning in SDS and label

The topic European Product Change Notification (PCN), including UFI and EuPCS has kept us as well as our users busy in this intense phase of preparation for the new, legally binding notification. In this small series, I summarise frequently asked questions and answers which arose during the webinars and the specialist conference. Part 1 of the series dealt with the legal deadlines, this part addresses the unique formula identifier (UFI).

UFI positioning in SDS and label for the European Product Change Notification (PCN)

Question: Where should the UFI appear in the SDS? The UFI is part of the product identifier and is therefore specified in Section 1.1 beside other numbers, such as the CAS No. of pure substances. Question: What is the deadline by which the SDS have to be revised? As long as the UFI can be found on the packaging, its specification in the SDS is optional. If the product does not have any packaging, the UFI has to appear in the SDS. For large-scale industrial use, it is also recommended that the UFI is placed in the safety data sheet.

Question: Does this mean that the emergency call information for poison emergency call centres can be omitted? No, the UFI and the related harmonised European Product Change Notification (PCN) harmonise the notification format but do not influence the obligation to display the already required emergency call information in the safety data sheet. Question: Can the UFI also appear on the barcode label? Or is it mandatory that it is positioned on the identification label? The ECHA guidelines indicate that the UFI is part of the identification label but that it can also be placed in the vicinity on the packaging for practical reasons, as long as the UFI is clearly visible and is located close to other labelling elements. Source: Guidance on harmonised information relating to emergency health response – Annex VIII to CLP, ISBN: 978-92-9481-265-0, 4.2.8

Sources:

• Regulation (EU) 2017/542: Annex VIII of the CLP Regulation (harmonised information relating to emergency health response and preventative measures), status 23/03/2017
• Information on change to end-user date on the websites of the poison centres.
• Guidance on harmonised information relating to emergency health response, Version 2.0, ISBN: 978-92-9481-265-0