Product Notification According to Article 45 of the CLP Regulation: What You Need to Consider Now

As of January 1, 2024, anyone in the EU placing hazardous mixtures such as paints, cleaning agents, and adhesives for industrial applications on the market must notify the ECHA (Poison Center Notification: PCN) of the mixtures’ formulations and product data in the prescribed and harmonized XML format. The ECHA then forwards the information to the poison information centers of the respective countries so that they can act quickly in case of an emergency. Article VIII of the CLP Regulation provides the applicable legal basis for this process. The reporting obligation under the CLP Regulation Annex VIII has been in place since January 2021 for mixtures used privately and commercially.

To Whom Does the Transition Period Apply?

If, as a company, you have already notified to the German Federal Institute for Risk Assessment (BfR) and/or the competent national authorities of other EU Member States about the mixtures before December 31, 2020, you benefit from a transition period. You have until January 1, 2025 to adapt the product notification to the new requirements of Annex VIII of the CLP Regulation. One restriction remains, however. If the trade name, formulation, or other properties – such as color or pH value – of the mixture change, you must act immediately and submit the required information in accordance with the currently applicable CLP requirements.

The Crux of the Recipe Identifier

As a result of the changes described, a new Unique Formula Indicator (UFI) is required. As of this year, the labels of all mixtures must clearly display this 16-digit code, unless the transitional period applies to this mixture. The affixing obligation applies as soon as a PCN notification is made in accordance with Annex VIII. That’s the only way to ensure quick identification of the mixtures in the poison information centers and the initiation of appropriate countermeasures. Last year’s inspections show that companies are struggling with legal compliance. In a letter from various national authorities to the ECHA, the authors complain that companies often use the same UFI for different mixtures. They therefore see education on the correct use of UFI codes as a key task.

Take advantage of the transition period and act now. We will be happy to support you, for example by checking the legal compliance of your notifications. For further support options and other questions, please contact us at


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