A Quick Guide On Product Notification in Switzerland
In Switzerland, the ordinance on protection against dangerous substances and preparations (ChemO) regulates the placing of substances and preparations on the market. The ChemO is largely similar to the European REACH and CLP regulations except when it comes to the part of registering substances.
Since January 2021, hazardous mixtures placed in the EU market are required to have a unique formula identifier (UFI) and submit information based on the poison centre notification (PCN) format. This requirement is outlined in CLP Art. 45 Annex VIII to harmonize emergency health responses. The UFI is introduced as a easy and quick way to identify mixtures in an emergency.
The Swiss ChemO has now taken the step to align themselves with the European requirement. In Switzerland, the UFI will be required for preparations, biocidal products, and fertilizers classified as hazardous based on their health and physical effects. The UFI complements existing notification obligations for preparations to the Swiss product register.
Swiss UFI Requirements
Notifications to the Swiss ChemO need to be done within 3 months of first placing the preparation on the market. Also, the UFI needs to be indicated on the products. The UFIs can be created using the UFI generator of the Swiss BAG (Swiss UFI Generator). This requirement will apply as follows:
- From 1.1.2022
- Preparations, biocidal products, and fertilizers that are newly placed on the market, which are intended for private users and are classified as hazardous on basis of their health and physical effects.
- Preparations, biocidal products, and fertilizer that are labeled with a UFI, because they were imported from the EEA need to submit this information. The BAG accepts UFIs created following CLP Art. 45, Annex VIII. This ensures that Tox Info Suisse can identify products quickly and reliably in an emergency.
- From 1.1.2026
- All other preparations, biocidal products, and fertilizers classified as hazardous based on their health and physical effects will need to have a UFI.
Poison Centre UFI and Swiss UFI
The Swiss UFI and Poison Centre UFI requirements are similar. The UFI must be affixed or printed on the label. However, note that UFIs that are generated with a Swiss VAT ID will not be accepted for Poison Centre Notification (PCN) in the European Economic Area. However, the Swiss BAG accepts UFIs created following CLP Art. 45, Annex VIII.
To help companies with handling their UFI creation and labeling, the BAG recommends the following:
- Whenever a product is already placed or will be placed on the EEA market, use the UFI created for notification in the EEA, i.e., use the UFI generated for the PCN format per CLP Art. 45, Annex VIII.
- If a product is solely placed on the Swiss market, use the Swiss UFI generator to create a UFI. Note here, the data requirements for reporting in Switzerland are different.
Software Support for SAP
Since 2013 our market-leading solution, opesus EHS Product Notification (EPN), supports notifications to the Swiss chemical register. We refer to this as the Swiss BAG format. With EPN you can register products en masse using the mass registration interface. Notifications are automatically generated in the required XML format.
We look forward to extending our solution to include the generation and submission of UFIs in alignment with the requirements of the Swiss ChemO. This depends on when the Swiss BAG can support UFIs in the XML format. We are already in contact with them to get insights into the new XML format and we plan to support them with testing.
Next Steps – What can you do now?
Assess the impact on your portfolio
In the first step, assess if you have any products that are placed on the Swiss market. After you’ve identified those products, assess if they are affected by notification obligations to the Swiss product register for chemicals. Specifically, products classified as hazardous on basis of their health and physical effects are affected.
Evaluate the best strategy for you
Once you have analyzed the impact of this regulation on your portfolio, it will be easier to figure out the options you have to ensure compliance. (link to resource article). If you would like to ease the notification process, leveraging a software solution such as opesus EPN is worth looking into. Nevertheless, we suggest acting early and not wait until the deadline to evaluate the best option for you.
Remember that the data requirements slightly differ from the data necessary for Poison Centre Notifications in the EEA. Therefore, utilize the time until the deadline and start preparation.