This time, I am writing about a request arising from practical concern regarding the different numbers for PCN. The European Product Change Notification (PCN) requires quite a few numbers and not all of them can be organised quickly. This is why here, I summarise all the numbers which we noticed when compiling the PCN for our program.
Why are numbers required for PCN?
The PCN is an electronic document which you have to supply starting in 2021 or 2024 if you bring hazardous substances into circulation in Europe, or more precisely within the scope of application of the CLP Regulation. Details are provided in our PCN blog series.
Checklist of all numbers for PCN
Two lists of numbers which are required for PCN are shown below. We continue to expand these lists as new findings arise. Afterwards, I will provide more detailed information on the different numbers. Unique numbers:
- VAT ID or replacement number (company key) for UFI creation
- Legal entity UUID and ECHA account for transfer to the ECHA portal
- System 2 system access for direct transmission to the portal from a program
- UFI, generated for your own product
- UFI of premixtures (MiM), if available
- Safety data sheet version number
- PCN UUID (is created for each notification, does not have to be made available)
The unique formula identifier (UFI)
The UFI is very prominent and mentioned frequently. Probably because it is to be found on labels and is completely managed by the manufacturers themselves if a product notification exists for the product. But there are always two other numbers behind the UFI.
- VAT ID / replacement number (company key)
- Sequential integer
This means that the VAT IT, followed by a sequential number, are used for its creation. In this way, the manufacturer can also determine which numbers they have already used. But the UFI makes it possible to work back to the VAT ID. If this is not wanted, a replacement number can also be used for UFI creation, which can be generated directly in the UFI generator on the ECHA page.
European product code (EuPCS)
At least one code from the European product categorisation system (EuPCS) is mandatory for each notified product. The list of all codes can be found on the Poison Centres website.
Legal entity UUID (LE-UUID)
Now we come to the more unusual, but of course also sensible requirements. You can easily create all the existing numbers for PCN and start using them straight away, but this number is more of a special case: If you want to access the ECHA portal to send your PCN, you have to specify the company it belongs to in the notifications and in your ECHA account. You can create the company as a “Legal entity” as soon as you have an ECHA account. If your company already exists as a legal entity, you can add new users to this company. The above-mentioned legal entity UUID can be found in the company settings. This number is also required in your product notifications. If the LE-UUID of the account does not match the LE-UUID in the notification, the notification is deemed to be incorrect and not approved by the ECHA submission portal.
Access to system 2 system (optional)
If you want to send your product notifications directly to the ECHA from your safety data sheet program, you need access to system 2 system. This access can be unlocked for your company (legal entity) on request to ECHA. Sources: CLP Regulation (EC) No. 1272/2008 consolidated version, status 01/01/2020 Regulation (EU) 2017/542: Annex VIII of the CLP Regulation (harmonised information relating to emergency health response and preventative measures), status 23/03/2017 Internet presence of the Poison Centres of the European Chemicals Agency (ECHA)