PCN & UFI: frequently asked questions

The submission of a hazardous mixture's full composition, toxicological information, product category, and packaging details to EU member state appointed bodies, in the harmonised format required by Annex VIII to the CLP Regulation. It must 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 receives the UFI can retrieve the exact formulation in seconds. It is generated from your VAT number (or a company key) plus a formulation number you assign.

The UFI is a code; the PCN is the notification behind it. Generating a UFI takes minutes and creates no obligation by itself. The PCN is the structured dossier submitted to ECHA's portal — the part that carries the legal duty. A UFI on a label without a matching PCN is a compliance failure, not partial compliance.

No — they have 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 obligation is now continuous: it attaches the day you place a mixture on the market.

Mixtures classified for health hazards or physical hazards under CLP, placed on the EU/EEA market. Mixtures classified only for environmental hazards are out of scope (voluntary notification is allowed), as are mixtures classified solely 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. ECHA's pilot enforcement project (reported February 2026) had inspectors in 18 EU/EEA countries check 1,597 mixtures: 19% of those requiring notification were not notified, and 15% had no UFI on the label. The follow-up REF-14 project is inspecting hazardous mixtures in consumer products throughout 2026, with a report due in 2027.

Penalties are set nationally under CLP Article 47 and vary widely — administrative fines in the tens of thousands of euros in several member states, with criminal provisions for knowingly false information in some (France's Code de l'environnement, for example, provides up to two years' imprisonment and €75,000 for that case). In the 2025 pilot, most findings first drew written rectification advice, but administrative orders, fines, and criminal complaints together accounted for roughly one in five enforcement actions.

Yes. If you sell a mixture under your own brand, you are 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 original and their product is already notified.

No — industrial-use mixtures have required notification since 1 January 2024. You may, however, qualify for the limited submission: reduced information up front in exchange for guaranteed rapid access to the full composition if a poison centre requests it.

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 directly through ECHA's S2S channel. All three deliver to the same portal and produce the same submission number.

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

ECHA's PCN format version 8 has been current since April 2026; version 7 (May 2025) preceded it. ECHA revises the format roughly annually alongside IUCLID releases. If you use Ufi Number, format updates are handled for you — dossiers are always built in the currently required format.

One ECHA portal submission can cover every member state you select — you pay attention to two caveats. As of ECHA's May 2026 overview, Bulgaria and Romania are flagged as not yet ready to receive dossiers via the portal, so check with their appointed bodies before relying on that route. And a few countries require confirmation of receipt before you may place the product on their market (Belgium, France, Germany, Italy, Luxembourg, Spain).

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

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

ECHA charges nothing — the portal is free. Costs come from three places: your time (ECHA's tooling has a steep learning curve), service fees if you outsource (consultants typically charge €300–1,000 per mixture; enterprise suites start around €5,000 a year), and national fees in a few member states. Ufi Number charges €20 per mixture.

Per ECHA's May 2026 member state overview: Belgium and Hungary levy fees set by their appointed bodies, and Italy charges registrants an annual fee (€50 per registrant per year to ISS). Belgium replaced its per-notification fees with an annual tiered structure from 1 January 2026 — verify the current tier with the Belgian appointed body. Everywhere else reports no fees.

ECHA still charges nothing for updates. National fee rules vary — Belgium's tiered annual fee, for instance, depends on the number of mixtures declared rather than per-submission events. With Ufi Number, resubmitting after ECHA feedback costs nothing extra.

Yes. UFIs are generated with ECHA's published algorithm from your VAT number (or a company key) and a formulation number, then validated before you see them. The same UFI you'd get from ECHA's own generator — created automatically, at the moment your mixture is saved.

ECHA doesn't run an approval programme for software vendors — no tool is "ECHA-certified," and any vendor claiming so is overstating. What exists is ECHA's official system-to-system submission channel, which requires ECHA-issued security keys per company. That's the channel we use, and every submission can be verified in your own ECHA account.

Under EU law, legal responsibility for accuracy stays with the company placing the mixture on the market — that's true whether you use us, a consultant, or ECHA's own portal. What we guarantee: the notification is built and formatted correctly, submitted through the official channel, and if your first submission fails ECHA's checks, we refund the credit and help you fix it.

All EU/EEA member states connected to ECHA's central notification system — one submission reaches the poison centres you select. The one exception in the EU is Bulgaria, which requires a direct national submission; we'll tell you before you submit, not after.

ECHA revises its required notification format regularly — most recently in 2026. When it changes, we update the engine and your existing dossiers remain valid to resubmit. You'll never be blocked by a format change you didn't know about.

Yes. Your mixture data, dossiers, submission numbers, and ECHA reports export at any time, in formats another tool or consultant can use. No lock-in is the point.