PCN group submissions and standard formulas: when the shortcuts pay off

Annex VIII to CLP is written for the general case: one mixture, one full composition, one notification. But four situations get special machinery — product ranges that differ only in fragrance, the cement/gypsum/concrete sectors, paints tinted at the point of sale, and fuels. Each mechanism trades a specific burden for specific conditions, and each stops paying the moment a condition breaks. Knowing where the break-points are is the difference between a shortcut and a trap.

Group submissions: one notification, many fragrance variants

A group submission (Part A Section 4) covers several mixtures in a single notification. The entry conditions are strict:

• every mixture in the group has the same classification for health and physical hazards;
• all mixtures contain the same components with the same reported concentration range for each component; and
• by derogation, the compositions may differ — but only in their perfumes, and the total concentration of the differing perfumes must not exceed 5% in each mixture.

The perfume derogation is the entire point in practice: detergent, air-freshener and cosmetic-adjacent ranges that share a base and differ per scent. The group must include a list of the mixtures and the perfumes each contains, including their classification, and each perfume must actually be present in at least one mixture of the group. Two further perfume concessions sweeten the deal: perfume components that are unclassified or classified only for skin sensitisation (category 1, 1A or 1B) or aspiration toxicity need no concentration declared, and — the operational win — changing or adding perfumes does not require a new UFI, only an update of the perfume list.

When it backfires: the group is coupled to its weakest member. If one variant’s classification drifts — a new perfume pushes a sensitisation threshold, a component reclassifies — that mixture no longer belongs in the group, and untangling one variant from a group record is more work than five standalone updates. Groups also concentrate risk in update mechanics: every change touches a record shared by the whole range. Group where the base is genuinely frozen and only the scent moves; notify individually where formulations evolve independently.

Standard formulas: cement, gypsum, ready-mixed concrete

Part D of Annex VIII publishes standard formulas — 20 for cements, one for gypsum binder, two for ready-mixed concrete — each a table of components with permitted concentration ranges. A mixture whose composition conforms to a standard formula may be notified against the published formulainstead of the plant’s exact composition, provided two conditions hold: the mixture’s classification does not change anywhere within the formula’s concentration ranges, and the formula-based information (plus normal declarations for any components outside the formula) is at least as detailed as the mixture’s SDS. If the SDS is more detailed, the SDS composition must be submitted instead.

The payoff is real for these sectors: batch-to-batch variability inside the formula’s ranges requires no updates at all — a submission update is due only when the composition stops conforming to the standard formula. That is also the trap. Add an admixture the formula does not list, or push one component past its published range, and the derogation evaporates retroactively for that product: you owe a full-requirements notification as a new notification after a significant change of composition, with a new UFI. Plants that routinely trial additives should treat the standard-formula boundary as a formal change-control gate.

Bespoke paints: the point-of-sale exemption

A bespoke paint is defined as a paint formulated in limited amounts, tailor-made for an individual consumer or professional user at the point of sale by tinting or colour mixing. Requiring a PCN and UFI per mixed shade would mean notifying near-unlimited combinations in advance or making the customer wait, so Delegated Regulations (EU) 2020/1677 and 2020/1676 built an opt-out: the mixer may choose not to notify and not to create a UFI for the bespoke paint itself.

The conditions moved to the label. Under Article 25(8) of CLP (inserted by 2020/1676), a bespoke paint with no notification of its own must carry the UFIs of all the notified mixtures it contains above 0.1%, listed together in descending order of concentration — and where such a mixture exceeds 5% of the bespoke paint, its concentration must be printed next to its UFI. The base paints and tinters, meanwhile, remain fully subject to Annex VIII: someone in the chain has notified each of them, or the scheme collapses.

When it backfires: the exemption relocates compliance from dossiers to point-of-sale label generation. The till has to produce a correct, per-batch supplemental label naming every qualifying UFI and concentration — an IT and training problem in every store, forever. Chains with controlled tinting systems handle this well; a merchant hand-writing labels does not. And a paint mixed in advance of demand, rather than for an individual customer at the point of sale, falls outside the definition and owes a normal notification.

Fuels: notify from the SDS

For the fuels listed in Part B Section 3.7 — automotive petrol (EN228), E85, alkylate petrol, LPG, LNG, diesel, paraffinic diesels such as HVO and GTL, heating oil, MK 1 diesel, aviation fuels, illuminating kerosene, heavy fuel oil, marine fuel and FAME/B100 — the composition may be submitted as the components listed in the safety data sheet, plus any other components you actually know. Fuels vary with crude slates and seasonal blending in ways a fixed composition declaration cannot follow, and recorded fuel poisonings are few; the SDS-based route acknowledges both.

The corresponding update rule cuts the other way: a submission update is due whenever Section 3 of the SDS is updated — even if the physical composition did not change — and a compositional SDS change brings a new UFI with it. Suppliers whose SDS documents churn for editorial reasons inherit notification work each time; a disciplined SDS revision process is part of the cost of this route.

Choosing a mechanism — and knowing when not to

None of these mechanisms changes who owes the notification or the baseline information requirements for everything outside their scope — and the use type rules apply unchanged on top. For a handful of fragrance variants on a stable base, a group submission genuinely saves money. For everything in between, notifying each mixture individually is often simpler than maintaining the conditions — at €20 per mixture through Ufi Number, the per-notification cost is rarely the deciding factor anymore.