UFI label requirements: how and where to print the code

The labelling rules for the UFI are short — Annex VIII Part A of the CLP Regulation disposes of them in a few sentences — but they are also the single most-checked item in poison centre enforcement, because verifying them takes an inspector seconds. This article sets out exactly what the regulation requires on the label, where the code may go, when the safety data sheet can carry it instead, and how to keep artwork processes from quietly breaking compliance.

What Annex VIII Part A requires

Three elements make a compliant UFI marking. First, the prefix: the code must be preceded by the acronym “UFI” in capital letters followed by a colon — UFI: GMTT-2SQN-6FDD-6TV1. Lower-case “ufi”, a translated acronym, or the bare code without the prefix all fail the letter of the rule; the prefix is what tells a poison centre call handler, in any language, which string on the label to ask for.

Second, presentation quality: clearly visible, legible and indelibly marked. In practice that means adequate type size and contrast against the background, no truncation at a seam or weld, and printing or marking that survives the product’s realistic life — a code that rubs off a solvent container or fades on an outdoor pack is not indelible. Note the phrase “printed on or affixed to”: a durable supplementary sticker is a legitimate way to add a UFI to existing stock, provided it meets the same visibility and permanence standard.

Third, the right code: the 16 characters, in four hyphen-separated blocks, exactly as generated. The format itself is covered in what is a UFI; how to produce one correctly in how to generate a UFI.

Where on the label it may go

Annex VIII does not prescribe a position. Companies commonly place the UFI near the barcode, near the hazard pictograms and other CLP label elements, or on the back label with the technical text — all acceptable, and so is anywhere else on the label, as long as visibility and legibility hold. Two practical conventions have emerged for good reason: keeping the UFI close to other information that emergency responders read (pictograms, hazard statements) speeds up the phone call, and keeping it in a consistent position across your range simplifies both artwork control and any future inspection.

What placement flexibility does not license is burying the code: inside a peel-back layer’s hidden face, under a flap that is destroyed on opening, or in a location that disappears when the packaging is partially used. The test is always whether someone holding the product mid-emergency can find and read the code.

When the SDS can carry the UFI instead

Two cases allow the UFI to live in section 1.1 of the safety data sheet rather than on a label: mixtures supplied without packaging (bulk deliveries — a tanker of screen wash has no label to print), and mixtures supplied for use at industrial sites, where the SDS is reliably present and the poison-centre call will come from a workplace with the document at hand. For industrial-site mixtures this is a choice — label or SDS — not an obligation to move it.

Choose one location and be consistent per product. A UFI in both places is fine; a UFI in neither, on the theory that the other document has it, is the finding waiting to happen. If your product portfolio spans consumer and industrial channels, remember the SDS option exists only for the industrial-site case — the consumer pack must carry the code on its label.

Multilingual labels: one UFI

The UFI is language-neutral — a code, not a phrase — so a multilingual label for several markets carries one UFI, once, not one per language block. The “UFI:” prefix itself is not translated. What does vary by market is everything around the notification: the member states selected and the submission languages, covered in our country guides. One label, one code, one composition — however many languages share the panel.

Relabelling, rebranding and reformulation

Label changes are where UFI compliance usually breaks, because the code on the artwork and the notification behind it must move together:

• Private labelling.Selling a mixture under your own brand makes you a duty holder: your own notification and, in the standard setup, your own UFI on your label — even if the composition is identical to the manufacturer’s original.
• Reformulation. A composition change beyond the ranges the notification permits means a new UFI on the new artwork and an updated notification before the reformulated product ships. The triggers are set out in when does a UFI change.
• Existing stock. Product already lawfully labelled does not need recall when a UFI changes for new production — but a transition period with two codes in the market means your register must map both codes to their compositions, and pickers must not mix artwork generations.
• Adding a UFI to legacy packaging.Durable stickers are permissible (“affixed to”), which is how most companies handled stock during the original compliance dates.

The enforcement picture

In the Enforcement Forum’s pilot project on poison centre notifications — 1,597 mixtures checked across 18 EU/EEA countries in the first half of 2025, results published February 2026 — 15% of inspected mixtures had no UFI on the label. The label check is the cheapest control an inspector has: no database query, no correspondence, just eyes on the pack. With the larger REF-14 project taking mixture inspections through 2026, a label with a missing, malformed or prefix-less UFI is the fastest route onto an inspector’s worksheet. What follows a finding — and the pilot’s full statistics — are covered in PCN enforcement.

Practical artwork checklist

• Exact string on the proof: UFI: in capitals, colon, the 16 characters in four hyphenated blocks — validated with a checksum tool (our UFI checkerruns ECHA’s algorithm in the browser) from the final artwork, not from the briefing email.
• Legible type size and contrast; no placement across a seam, weld or die-cut.
• Print method rated indelible for the product’s chemistry and storage life.
• One UFI per label, regardless of language count.
• Artwork change control: any composition change order triggers a UFI review before plates are made.
• Register updated: this artwork version, this UFI, this composition, this notification’s submission number.

Teams using Ufi Number get the code and the notification from the same record, which removes the failure mode where the label and the dossier drift apart — but the artwork checks above remain yours either way.