Now Is the Time to Ensure the Marketability of Your Hazardous Mixtures After 2024: Product Notification According to Article 45 of the CLP Regulation

On January 1, 2025, all notifications for hazardous mixtures regarding physical and health hazards that were created in a national format will become invalid. It is therefore important for importers, manufacturers, and distributors to review their product notifications as quickly as possible and update them if necessary. To do so, they must report the product data and formulations of their hazardous mixtures as part of the PCN procedure in the prescribed PCN format. Furthermore, from 2025 onward, a unique formula identifier (UFI) must be printed on the label and packaging of all hazardous mixtures. This code can be used to quickly determine the composition of the mixture in an emergency.

Annex VIII of the CLP Regulation provides the legal basis for the reporting obligation. Its requirements ensure that emergency medical measures can be taken quickly in the case of poisoning. To this end, the ECHA forwards the information from importers, manufacturers, and distributors to the poison information centers of the countries in which the mixture is marketed so that they can act immediately if they receive an emergency call.

What to Consider

Regarding conventional national product notification, those affected should know that hazardous mixtures submitted in a national format (XProduct Notification in Germany) are valid until December 31, 2024.

It is important that the products are on the shelf with the UFI as of January 1, 2025. That means that you should start the notification and labeling in good time so that you meet the deadlines. Otherwise, you are obliged to relabel the goods with the UFI, even if the products have already been delivered.

Deadline: January 1, 2025

The product notification must be available in PCN format by this date so that the hazardous product remains marketable. A UFI must be affixed to all products, including products already delivered. On the same date, the validity of all notifications for hazardous products made in national format (XProduct Notification) will expire.

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  • analyze the status quo and plan the next steps
  • developing and defining the notification process
  • with all steps of the notification process
  • in fulfilling all obligations associated with the product notification

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