REF-14 inspection readiness: the 2026 mixture enforcement project

REF-14 is the ECHA Enforcement Forum’s coordinated enforcement project on hazardous mixtures, with inspections across the EU and EEA through 2026. It’s easy to confuse with the Forum’s 2025 pilot project on poison centre notifications. The figures you may have seen, such as 19% of mixtures not notified, come from the pilot, reported in February 2026 (ECHA/NR/26/08). This page keeps the two apart and ends with a checklist you can run on your own records.

What REF-14 is

REF projects are the Enforcement Forum’s instrument for coordinated, EU-wide inspection campaigns: member states agree a scope, train inspectors against a common methodology, inspect in parallel, and publish a joint report. REF-14 applies that to mixtures. Preparation and training ran to the end of 2025, the inspection phase runs through 2026, and the consolidated report is expected in 2027. National enforcement authorities do the inspecting. REF-14 gives them a shared checklist and a reason to prioritise mixtures in 2026.

The scope is broader than poison centre duties alone. Inspectors will check classification, labelling, packaging (including child-resistant fastenings), poison centre notifications, and the safety data sheets of hazardous mixtures in consumer products, alongside compliance with REACH restrictions and the POPs Regulation. For a company whose CLP fundamentals are in order, the PCN and UFI duties are the newest, and so the place to start checking. The broader obligations are covered in PCN enforcement.

REF-14 is not the pilot, and the numbers belong to the pilot

In 2025 the Forum ran a pilot project specifically on poison centre notifications: 18 EU/EEA countries, 1,597 mixtures checked between January and June 2025, report published in February 2026 (ECHA news ECHA/NR/26/08). It was smaller and narrower than REF-14: a test of whether PCN compliance could be inspected in practice, given that national authorities have no automatic right of access to the PCN database.

Some commentary since has blended the two projects into one “ECHA crackdown”, attributing the pilot’s findings to REF-14. Keeping them apart matters for planning: the pilot is finished and its numbers are on the record; REF-14 is the live project, its scope is wider, and its results aren’t published yet. What the pilot supplies is evidence of where inspectors found problems in 2025.

What the pilot found

All figures below are the pilot’s, from the February 2026 report:

• 19% not notified. Of the 1,432 inspected mixtures that required a PCN, no notification existed for 19%. This was the single most frequent failure.
• 15% without a UFI on the label. Where the UFI was required on the label, it was missing in 15% of checked mixtures. Where a UFI was present, its format was valid in 98% of cases: companies that engage with the duty largely get the code itself right.
• 71% of inspected mixtures came from SMEs, with compliance rates at a similar level for SMEs and large companies. SMEs aren’t worse at this; they were most of the sample.
• Consistency failures beyond the headline rates. For 13% of notified mixtures the label and the notification disagreed, and the PCN was inconsistent with the SDS in 17% of cases: trade names, volumes and labelling elements drifting apart across documents maintained in different systems.
• 656 non-compliant cases drew enforcement action: written advice in 68% (447 cases), verbal advice 15%, administrative orders 11% (72 cases), fines 5% (30 cases), criminal complaints 4% (29 cases).

Two of these checks are quick to run, for an inspector and for you: whether a notification exists, and whether the UFI is on the label. They’re the place to start on your own records.

How a typical inspection unfolds

The pilot ran inspections on-site (28%), as desk checks (32%), or both (41%), with mixtures selected off market shelves, through risk-based targeting, or via customs data. From the duty holder’s side, the sequence looks like this:

1. A product is picked, sometimes off the shelf, which means the inspector starts from your consumer-facing label rather than your records.
2. Label check. Classification elements, and the UFI: present, prefixed “UFI:”, correctly structured, correctly placed under Article 25 CLP. The formal rules are in UFI label requirements.
3. Database lookup. The inspector, via the national appointed body or poison centre, checks whether a notification exists for that UFI in that market.
4. SDS cross-check. Section 1.1 (does it carry the UFI where required), section 3.2 against the notified composition, section 11 against the notified toxicological information.
5. Follow-up with the duty holder. Questions about anything inconsistent: who notified, when, for which markets, and whether updates kept pace with reformulations.

A readiness checklist you can run on your own records

• Reconcile the portfolio. One list of every mixture you place on the market, one column of PCN submission numbers. Every gap is either an exemption you can name (check whether each product needs a PCN) or a missing notification.
• Check labels against notified UFIs. The code on current artwork must match the code in the notification, character for character. The pilot found label-notification mismatches in 13% of notified mixtures.
• Check SDS section 1.1. For unpackaged and industrial-supply cases where the UFI lives in the SDS, confirm it’s there. The pilot’s small sample of this case showed 25% non-compliance.
• Document MiM chains. For every mixture-in-mixture component, record the supplier UFI or supplier details you relied on, so a question about a component has its answer on file.
• Clear the update backlog. Each reformulation, new market or changed trade name needs an updated notification.
• Make records retrievable in one day. Submission numbers and dossier copies, per product, findable by whoever answers the phone.

If an inspector finds a gap

For anyone acting in good faith, the pilot’s enforcement profile is the reassuring part of the report: 68% of actions were written rectification advice, which means fix it and show you fixed it. Formal measures were the minority: administrative orders in 72 cases, fines in 30, criminal complaints in 29. The advice asks for the fix and the evidence of it. Submit the missing poison centre notification straight away, correct the label at the next print run with a documented timeline, and reply to the authority with submission numbers in hand.

If the reconciliation turns up a backlog, you can clear it yourself in ECHA’s portal, and ECHA charges nothing. UFI Number is built to take a mixture from formulation data to a submitted notification with its submission number on file. It’s in private beta.