Strategies for Implementing UFIs

UFI requirement EU

The unique formula identifier (UFI) is the unambiguous identifier of products classified for health or physical hazards. From 1st January 2021, this 16-character code must appear on or in proximity to product labels.

The UFI will be used by poison centres in the event of an emergency call. Therefore, upon submitting a notification to the ECHA Submission Portal, only poison centres will know which mixture composition the UFI corresponds to. Our FAQ on UFI covers questions and answers about UFIs, including how you can generate a UFI.

In this article, we will explore the different strategies for implementing a UFI. As a UFI is meant to be the unambiguous identifier of the mixture composition of a product, it is not allowed to use the same UFI for products with different mixture compositions. You can however create multiple UFIs for the same mixture composition and assign them to products of this mixture composition. A case for the latter is when you have the same product, which utilizes the same mixture but has different brand names to meet different market segments.

Strategy 1: Generate One UFI for One Mixture

This is the most straightforward way of generating UFIs – one UFI represents one mixture. We generally do not advise using this strategy exclusively if you have a complex portfolio. In the real world, the same mixture may be sold under different names, at different price points, and to different sales accounts.

Therefore, the exclusive use of this strategy is useful only if you have a handful of products or if you have a strict 1:1 relationship between formulas and products. If data is maintained consistently, where 1 specification is linked to materials that represent different packaging sizes but the same trade name, then this strategy is also suitable for your company.

Strategy 2: Multiple UFIs for One Mixture

This strategy is most commonly used for generating UFIs. In real-life scenarios, we know that the same chemical formula may have various uses or are branded differently to suit various market segments. Listed below are scenarios where you might want to generate several UFIs for one mixture.

Do note that the approaches described below can be considered if you’re using SAP EH&S to manage your chemical products.

One Mixture Sold Under Different Brands – Generate Brand-Specific UFIs

If the same mixture or formula is sold under various brand names, you want to generate several UFIs. This is because it is your confidential business information that the same formula is sold under different brands. Therefore, you should generate a different UFI for each brand.

One Mixture Sold Under Country-Specific Names – Generate Country-Specific UFIs

This strategy is relevant if you have country-specific trade names. For example, the same cleaning product is sold under different trade names in different countries. In this case, you would have to consider the trade names and language-specific names that you have stored for a specification in SAP EH&S.

One Mixture Sold with Customer-Specific UFIs

In a scenario where the same mixture is sold to several customers for various uses, you might want to generate customer-specific UFIs. For example, a mixture that is formulated as a generic glass cleaner may be sold as a household cleaning product or part of the professional car-cleaning kit. In this case, you would have to consider where such information is stored, for example in the customer material info record.

UFIs for Non-Hazardous Mixtures

CLP Art. 45, Annex VIII on the harmonized format for emergency response outlines that notifications are mandatory for mixtures classified for physical and health hazards. How about non-hazardous mixtures?

While it is not mandatory to generate a UFI and submit a notification for non-hazardous mixtures, you may find it helpful to submit a voluntary notification. There are two cases for this:
(1) it might help poison centres in case they do receive calls regarding non-hazardous mixtures, and
(2) it protects your confidential business information. In scenarios of mixtures-in-mixtures, you can communicate the UFI of your mixture instead of informing your customer about the composition. According to ECHA, in such cases, you need to submit the notification, but it is optional to add the UFI on the product label.

Where to Begin?

The repercussions of the UFI requirement are a lot more complex than simply generating a 16-digit code and affixing them on the labels of your products. A UFI is only valid after it is accepted at ECHA. Compound that with the fact that a product can only be placed on the market with a valid UFI – one needs to consider the complete business process. When should a UFI be printed? When should it be affixed? When can logistics move a product?

With opesus EHS Product Notification, we’ve worked with over 60 customers to discuss their requirements. Our rich knowledge enables us to give you advice on the most applicable scenario for your company. Furthermore, we have designed our software to support scenarios beyond what has been described in this article. Contact us and schedule a non-binding introductory call for opesus EPN.