PCN & UFI: frequently asked questions

The submission of a hazardous mixture's full composition, toxicological information, product category and packaging details to the appointed bodies of EU member states, in the harmonised format Annex VIII to the CLP Regulation requires. It has to be done before the mixture is placed on the market.

The Unique Formula Identifier: a 16-character code printed on the label that links a product to its notified composition. A poison centre responder who has the UFI can retrieve the exact formulation. It's generated from your VAT number (or a company key) plus a formulation number you assign.

The UFI is a code, and the PCN is the notification behind it. Generating a UFI takes a minute and creates no obligation by itself. The PCN is the structured dossier submitted to ECHA's portal, and that's where the legal duty sits. A UFI has no legal effect until the mixture is notified.

No. They've all passed. Consumer and professional use became mandatory on 1 January 2021, industrial use on 1 January 2024, and the transition period for products notified under old national systems ended on 1 January 2025. The duty is now continuous: it starts the day you place a mixture on the market.

Mixtures classified for health hazards or physical hazards under CLP and placed on the EU/EEA market. Mixtures classified only for environmental hazards are out of scope (voluntary notification is allowed), and so are mixtures classified only as gases under pressure or certain explosives.

The duty holder: the importer bringing the mixture into the EU/EEA, or the downstream user who formulates, rebrands or repackages it. From 1 January 2027, the 2024/2865 CLP revision also brings distributors into scope in defined cases. Liability stays with the duty holder even when a consultant or software prepares the submission.

Yes. When inspectors in 18 EU/EEA countries checked 1,597 mixtures in the first half of 2025, 19% of the ones that needed a notification didn't have one, and 15% had no UFI on the label (ECHA/NR/26/08, 11 February 2026). A targeted enforcement project, not a measure of the whole market. The follow-up REF-14 project is inspecting hazardous mixtures in consumer products through 2026, with a report due in 2027.

Each member state sets its own under CLP Article 47, and they vary widely. Several have administrative fines in the tens of thousands of euros, and some have criminal provisions for knowingly false information: France's Code de l'environnement, for example, provides up to two years' imprisonment and a €75,000 fine for that case. In the 2025 pilot, most findings first drew written advice. Administrative orders, fines and criminal complaints together made up roughly one in five enforcement actions (ECHA/NR/26/08).

Yes. If you sell a mixture under your own brand, you're the duty holder for that product. You need your own PCN and normally your own UFI, even if the composition is identical to the supplier's and their product is already notified.

No. Industrial-use mixtures have needed a notification since 1 January 2024. You may qualify for the limited submission: reduced information up front, with a duty to give a poison centre rapid access to the full composition if it asks.

By one of three routes. Prepare the dossier in ECHA's IUCLID Cloud and upload it through the ECHA Submission portal; prepare it offline in IUCLID 6 and upload the .i6z file; or submit system-to-system, where software sends the dossier straight through ECHA's S2S channel. All three arrive at the same portal and return the same kind of submission number.

The full composition with concentrations or permitted ranges, the mixture's classification and toxicological information, the UFI, the EuPCS product category, the use type, packaging types and sizes, label information and the submitter's details. Industrial-use-only mixtures may use the reduced "limited submission" set.

Version 8 of ECHA's PCN format, current since April 2026. Version 7 (May 2025) came before it, and ECHA revises the format roughly once a year alongside IUCLID releases. UFI Number is built to keep the format current, so each notification is prepared in the format ECHA requires at the time.

Yes, with two conditions. One ECHA portal submission can name every member state you select. As of ECHA's May 2026 overview, Bulgaria and Romania are flagged as not yet ready to receive dossiers through the portal, so check with their appointed bodies before you rely on that route. And six countries need confirmation of receipt before you may place the product on their market: Belgium, France, Germany, Italy, Luxembourg and Spain.

It depends on the member state. Croatia, Denmark, Germany, Ireland, the Netherlands, Sweden and others accept English. Austria, France, Greece, Hungary, Poland and others require their official language only. Finland requires Finnish and Swedish. Check the target country's row in the country table before you submit.

In most member states, as soon as the submission report shows the dossier passed ECHA's validation rules. In Belgium, France, Germany, Italy, Luxembourg and Spain, you wait until the report confirms the national appointed body has received the dossier.

ECHA charges nothing. The portal is free. The cost comes from three places: your time, because ECHA's tools take time to learn; service fees if you outsource, where consultants quote per notification and enterprise suites sell an annual licence; and national fees in Belgium, Hungary and Italy. UFI Number is in private beta. It's pay as you go, one notification at a time, with no subscription and no annual licence.

Belgium, Hungary and Italy, per ECHA's May 2026 member state overview. Italy charges an annual fee of €50 per registrant to ISS. Belgium's fee is per notification, with amounts set by the type of change, and invoiced by FPS Public Health, so check its current fee table. Everywhere else reports no fees.

ECHA charges nothing for updates either. National fees differ: Belgium's depends on the type of change notified, and Italy's is a flat annual amount per registrant. UFI Number is built so that a resubmission after ECHA feedback is part of the same step.

No. A UFI from the generator is the same code ECHA's algorithm produces for that VAT number and formulation number. A UFI has no legal effect until the mixture is notified.

No, and nobody is. ECHA doesn't approve or certify software vendors, so no tool is ECHA-certified. What exists is ECHA's official system-to-system submission channel, which needs ECHA-issued security keys for each company. That's the route UFI Number is built to send through, and every submission made through it shows in your own ECHA account.

The company placing the mixture on the market. Under EU law, legal responsibility for accuracy stays there whether you use us, a consultant or ECHA's own portal. UFI Number is built to prepare the notification in the current format, send it through ECHA's official system-to-system route and keep the submission number ECHA returns in your records. Sending to ECHA is not live yet.

All EU/EEA member states connected to ECHA's central notification system, and one notification can name the markets you select. Bulgaria and Romania are not yet receiving notifications through ECHA, and UFI Number is built for ECHA's route only, so it doesn't cover their national requirements.

ECHA revises its notification format regularly, most recently in April 2026 (format version 8). When it changes, UFI Number is built to prepare your notifications in the new format.

Yes. UFI Number is built so that your mixture data, prepared notifications and submission records can be exported at any time, in formats another tool or consultant can use. No lock-in is the point.