What Is a UFI Code and Do You Need One?

1. What Is a UFI Code?

A Unique Formula Identifier (UFI) is a 16-character alphanumeric code that creates a direct link between a commercial product and the exact chemical composition of its hazardous mixture, as stored in the ECHA Poison Centre database. It was introduced by Commission Delegated Regulation (EU) 2017/542, which added Annex VIII to the CLP Regulation (EC) No 1272/2008.

The purpose is straightforward: when someone is accidentally exposed to a product — through ingestion, skin contact, or eye contact — poison centre staff can instantly look up the exact formulation by scanning or entering the UFI. This enables faster and more accurate medical treatment, replacing the old system where emergency responders had to identify the product by trade name alone, often leading to delays and ambiguity.

The format is always the same: UFI: XXXX-XXXX-XXXX-XXXX

The code is always preceded by the letters "UFI" in capitals. The 16 characters are separated into four groups of four by hyphens. Each character is alphanumeric. The UFI is deterministic: it is generated from a combination of your company's VAT number and a formulation number you assign, so regenerating the code with the same inputs will always produce the same result.

2. Who Needs a UFI Code?

Any company that places a hazardous mixture on the EU market needs a UFI. Under the CLP Regulation (EC) No 1272/2008, a "hazardous mixture" is any mixture that meets the classification criteria for health or physical hazards. In practice, this covers an enormous range of consumer and professional products:

• Candle makers — scented candles with classified fragrance ingredients (virtually all scented candles)
• Wax melt sellers — same fragrance-based classification as candles
• Essential oil sellers — essential oils are almost universally classified as hazardous under CLP
• Perfume manufacturers — fragrance concentrates and finished perfumes
• Cleaning product makers — household and commercial cleaners, detergents, degreasers
• Paint manufacturers — coatings, varnishes, stains, and paint removers
• Adhesive makers — glues, sealants, and bonding agents
• Cosmetics with hazardous mixtures — nail polishes, hair dyes, certain skincare products

The key question is not what industry you are in, but whether your product is classified as hazardous under CLP. If it is — and the vast majority of scented candles, fragrance products, and cleaning products are — you need a UFI.

3. UFI Timeline and Deadlines

The UFI requirement was phased in over several years, with different deadlines for different use categories. Here are the critical dates:

4. How to Generate a UFI Code

Generating a UFI is a straightforward process using ECHA's free online tool. Here is the step-by-step process:

• Step 1: Go to ECHA's free UFI Generator at https://ufi.echa.europa.eu/. The tool is web-based, requires no installation, and is available in all EU official languages.
• Step 2: Enter your company's VAT number or company key. This ties the UFI to your legal entity. You can use your EU VAT number, or if you don't have one, ECHA provides a company key alternative that you can generate in the tool.
• Step 3: Assign an internal formulation number. This is your own tracking reference — any number you choose to identify the specific formulation within your product range.
• Step 4: The tool generates a unique 16-character UFI. The code appears immediately and can be copied. It follows the standard format: UFI: XXXX-XXXX-XXXX-XXXX.
• Step 5: Record the UFI and link it to your specific formulation in your internal records. You will need this mapping when submitting Poison Centre Notifications and when updating labels.

Important: generating the UFI is only half the job. The code by itself is meaningless without a corresponding Poison Centre Notification. The next section covers the notification requirement.

5. Poison Centre Notification (PCN)

The UFI exists to link a product to its composition in the Poison Centre database. For that link to work, you must submit a Poison Centre Notification (PCN) through the ECHA submission portal. The PCN is the record that tells poison centre staff exactly what is in your product when they look up the UFI during an emergency.

What the PCN includes

• Complete mixture composition — every ingredient, including CAS numbers and concentration ranges.
• The UFI — linking this notification to the code on the product label.
• Product category — selected from the European Product Categorisation System (EuPCS), which classifies products by their intended use.
• Product name — the trade name as it appears on the label and in commerce.
• Colour — the visual appearance of the mixture.
• Packaging type — the type of container the product is sold in.
• pH — where applicable and measurable.
• Intended use — consumer, professional, or industrial.

Harmonized format replaces national submissions

Before the harmonized system, companies had to submit separate notifications to each EU member state's appointed body, using different formats and languages. The current system under Annex VIII of CLP replaced that with a single harmonized notification that covers all 27 EU member states. You submit one PCN through the ECHA portal, and it is distributed to the relevant national poison centres automatically.

6. One UFI Per Formulation — The Key Rule

This is the single most important rule to understand: each unique mixture formulation gets its own UFI. The UFI is tied to the composition of the mixture, not to the product name, brand, size, or packaging. Here is how that works in practice:

The practical implication: if you are a candle maker with 20 different scents, you need 20 separate UFI codes and 20 separate Poison Centre Notifications. If you reformulate one of those scents — even a minor adjustment to the fragrance blend percentages — you need a new UFI and an updated PCN for that formulation.

If the same formulation is sold under different brand names or in different packaging, it can share the same UFI. The code follows the formulation, not the marketing.

7. How to Display the UFI on Your Label

The UFI must appear on the product label following specific rules defined in Annex VIII, Part A, Section 5 of the CLP Regulation:

• Preceded by "UFI" in capital letters — the acronym "UFI" must always appear before the code itself. This ensures the code is identifiable even by someone unfamiliar with the system.
• Clearly visible and legible — the UFI must not be obscured, hidden, or printed in a way that is difficult to read. It should contrast sufficiently with the background.
• Indelible — the UFI must be printed in a permanent manner. It cannot be on a removable sticker that might fall off, unless that sticker is the primary label.

Where to place the UFI

• The product label itself (the most common placement)
• The packaging (outer box, wrapper, or sleeve)
• A supplementary label affixed to the product or packaging

Best practice is to place the UFI near the other CLP label elements — alongside the hazard pictograms, signal word, and H/P statements. This ensures all safety information is in one place and is easily found by emergency responders.

Font size requirements

There is no specific font size mandated in the regulation. The requirement is that the UFI be "legible" — which in practice means it should be at least 1.5mm x-height (the height of a lowercase letter like "x"). Using the same font size as your other CLP label text is a safe approach.

8. Who Submits the PCN?

The obligation to submit a Poison Centre Notification falls on the duty holder. Under Annex VIII of CLP, the duty holder is the importer or downstream user who places the hazardous mixture on the EU market. Understanding who that is in your supply chain is critical:

• EU-based manufacturers: If you manufacture the mixture within the EU, you are the duty holder and must submit the PCN.
• Non-EU sellers (e.g., US-based companies): Your EU Responsible Person or importer is typically the entity placing the product on the EU market. They bear the notification obligation unless you arrange otherwise.
• Distributors and retailers: If you sell a product that someone else has already placed on the EU market, the original importer or downstream user is the duty holder — not you — unless you rebrand or reformulate the product.

You can appoint a third party (such as a regulatory consultant or compliance service) to submit the PCN on your behalf. However, the legal responsibility remains with the duty holder. Using a third party does not transfer liability — it simply delegates the administrative task.

9. UFI Costs and Practical Considerations

One of the most common questions about UFI codes is how much they cost. The short answer: the tools are free, but compliance takes time and effort.

What is free

• The ECHA UFI Generator — completely free to use, no account required, unlimited UFI generation.
• The ECHA Poison Centre Notification portal — free to submit notifications. No government fees, no per-submission charges, no annual licensing costs.

Where the real costs are

• Preparation time: Compiling the full composition data for your PCN requires obtaining detailed formulation information from your fragrance or chemical supplier. This can be time-consuming, especially if your supplier is reluctant to share full ingredient breakdowns.
• Compliance consultant fees: If you cannot navigate the ECHA portal yourself, hiring a regulatory consultant typically costs $200–$1,000 per formulation depending on complexity and number of ingredients.
• Label reprinting costs: Adding the UFI to your existing labels may require a redesign and reprint run. This varies widely depending on your label format and print quantities.

Example: candle maker with 20 scents

For a candle maker with 20 unique fragrance formulations, the compliance workload looks like this:

• 20 UFI codes generated through the ECHA tool (free)
• 20 PCN submissions through the ECHA portal (free, but each requires full composition data)
• 20 label updates to add the UFI code to each product label
• If using a consultant: $4,000–$20,000 total (at $200–$1,000 per formulation)

The ongoing cost is maintenance: every time you reformulate, you need to update the PCN and potentially generate a new UFI. Seasonal or limited-edition scents each require their own separate submission.

10. Common UFI Mistakes

Based on enforcement trends and marketplace compliance audits, these are the most frequent errors companies make with UFI requirements:

Not generating a UFI at all

This is the single most common mistake, particularly among small businesses and artisan sellers entering the EU market for the first time. If your product is classified as hazardous under CLP, the UFI is not optional.

Using the same UFI for different formulations

Each unique formulation needs its own UFI. Using one code across multiple scents or product variants defeats the purpose of the system — poison centre staff would be looking at the wrong composition data.

Forgetting to update the PCN after reformulation

If you switch fragrance suppliers, adjust concentrations, or add/remove ingredients, the PCN must be updated. Depending on the change, a new UFI may also be required.

Placing the UFI on the outer shipping carton instead of the consumer-facing label

The UFI must be on the product packaging that the end user sees and retains, not on a transit box that gets discarded by the retailer.

Omitting the "UFI" prefix

The code must always be preceded by the letters "UFI" in capitals. Printing just the 16-character code without the prefix is non-compliant.

Generating the UFI without submitting the PCN

Having the code on your label without a corresponding Poison Centre Notification is useless. The UFI is a lookup key — if there is no record to look up, the system fails when an emergency occurs.

Confusing UFI obligation with REACH registration

These are separate regulatory requirements. REACH registration covers the substances themselves and is the obligation of the substance manufacturer or importer. The UFI/PCN obligation applies to the company placing the mixture on the market. They are different obligations, different portals, and different legal bases.