By Ziannah Pasion
Background
During a recent webinar, ECHA clarified recent updates to the CLP Regulation concerning Poison Centre Notifications (PCN), provided practical guidance on managing UFI codes, and addressed what actions are required after the end of the transition period on 1 January 2025.
The most significant change lies in ECHA’s updated interpretation regarding mixtures already placed on the market before that date. Previously, ECHA stated that mixtures notified under Article 45 of the CLP and placed on the market by a distributor before 1 January 2025 did not need to be relabelled with the UFI, provided the obligation had already been fulfilled by the upstream supplier (importer or downstream user) in line with the application dates—1 January 2021 for consumer and professional use, and 1 January 2024 for industrial use.
What is ECHA’s new position?
ECHA now states that from 1 January 2025, mixtures already on distributors’ shelves may no longer be supplied if the UFI code is not present on the label. In such cases, the products would be considered non-compliant with CLP.
In line with this new position, ECHA recently updated Q&A No. 1727, clarifying that distributors and retailers must request the UFI from their suppliers and ensure it is affixed, even via a label sticker.
Downstream users, importers, and distributors involved in rebranding or relabelling are also responsible for providing the UFI code.
ECHA confirmed that this interpretation has been agreed upon with all national helpdesks.
What should you do now?
While awaiting further guidance from national authorities, we recommend that all companies:
✔ Check current stock to ensure that all labels include the required UFI code
✔ Assess whether relabelling is necessary, especially for products already distributed or ready for sale
Applying a sticker with the correct UFI is an acceptable solution in most cases.
