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Essential Information - Changes to packaging as a result of EU legislation
Published: 09 April 2019
As a result of a change in EU legislation, article 45 of CLP, there are some essential changes coming to the packaging of products containing hazardous properties. All packaging must contain a UFI number, a 16-character code which will be used by poison centres for emergency health response purposes in case of incidents involving the product.
The changes will apply to goods containing hazardous properties, including most household cleaning products and paint, as well as adhesives, coatings and primers.
These changes need to be in place by as early as January 2020 for products intended for consumer use. However by registering your product data now with the applicable poison centre for each EU member state your product is sold into, you can benefit from an extended transitional period until January 2025 – which will allow for better planning and a smoother transition. More information is detailed below.
What is a UFI?
The UFI's position on an Apollo label
A new label element will need to appear on product labels from 2020 – a 16-character alphanumeric code called the unique formula identifier (UFI). By 2025, the UFI will be mandatory on the label of all products that contain a hazardous mixture, i.e. classified for health or physical hazards.
Those placing such products on the market will have to provide specific product information, including the UFI, to poison centres. If you place our product on the market under your brand, you will need to register your product and create your own individual UFI – Apollo cannot do this for you.
When are the changes required?
Your company will be obligated to have notified poison centres of the UFI and other product information by the following deadlines:
- 1 January 2020 for products intended for consumer use
- 1 January 2021 for products intended for professional use
- 1 January 2024 for products intended for industrial use only
For new products, you must submit the required information before you place the mixture on the market. We will require you to provide us with your UFI code for new products. Products already on the market can benefit from a transitional period, until 1 January 2025, if you register your product data and Safety Data Sheets (SDS) with the applicable poison centre for each EU member state your product is sold into. By 1 January 2025, all relevant products on the market will be required to bear the UFI on the label.
You need to be ready with your UFI on the label before your deadline to submit this product information to the applicable poison centres. This means that the generation of UFIs and the printing of appropriate product labels needs to be carefully planned into schedules – this is why we highly recommend submitting this data and benefiting from the extended transitional period.
WHAT YOU NEED TO DO NOW: Register your product data to benefit from the transitional period
You can benefit from the extended transitional period of the 1st January 2025, if you register your product data and SDS now with the applicable poison centre for each EU member state your product is sold into. You have until 1st January 2020 to submit this data; otherwise you will have to abide by the above deadlines.
For the UK, the appointed body is National Poisons Information Service (NPIS): http://www.npis.org/. This just involves simply sending over your branded SDSs to email@example.com to be able to benefit from the transitional period.
The list of poison centres for other EU member state can be found here: https://poisoncentres.echa.europa.eu/appointed-bodies.
Apollo have provided all of our own Apollo created and named SDSs to the NPIS, the poison centre for the UK – this means no UFI is required on Apollo branded products sold in the UK until 2025. If you place our product on the market as your own branded product, we highly recommend you do the same. This means you will have until 1 January 2025 to transition.
WHAT’S NEXT: Creating a UFI number
The next step is to create your specific UFI numbers for your products. By registering your product data and SDS with the applicable poison centres - you will have until January 2025 to complete these next steps. To create a UFI, you need your company’s VAT number and a mixture-specific formulation number. Entering these two numbers into ECHA’s UFI Generator online tool will provide you with your UFI code. Find out more information here.
If you require any further information in the meantime, please contact your Account Manager or Apollo's Compliance department.