UFI code and harmonised toxicological notification – Current status

On 29th November the resolution of the last meeting held between the Competent Authorities for REACH and CLP (CARACAL) was published. The European commission agreed on amending the text for the CLP Annex VIII, which refers to harmonised toxicological notifications and the use of the UFI code. The new draft includes several amendments where the most relevant ones are:

  • • Text clarification to avoid ambiguities.
  • • Change of the compliance date for hazardous mixtures for end users, postponing the date one more year: January 1st, 2021.

The text is being currently under revision by the European Parliament and European Council until December 29th, 2019. After this date, the final document will be published in the Official Journal (date unconfirmed yet) entering into force 20 days after its publication. It is expected that the final new document will be in force in mid-January, being official the old requirements during the first days of the 202 year.

transition period

AISE (International Association for Soaps, Detergents and Maintenance Products) remind us that the time from January 1st, 2021 to January 1st, 2025 is a transition period for the new Annex VIII. It means that, the products nationally notified before the first deadline can be placed on the market without needing an information update until beginning of 2025. For example, if in the last years we have notified our mixture to a national institute of toxicology, it will not be necessary to update such information until 2025, independently if we have decided to include the UFI code to our label or not. So, in case the product has suffered any modification (formulation, labelling, classification ...), it is advisable to make a new notification in order to be compliant with the 2025 deadline.

UFI harmonized

Regarding the UFI harmonized, it is going to be only mandatory once the Annex VIII entries into force, therefore, when a new toxicology notification is made after January 1st, 2021 our labels and SDS must have the UFI. On the contrary, for notifications made before 2021, it will not be mandatory until the end of the transition period (January 2025).

In a nutshell…

  • • The new Annex VIII text will be published in mid-January 2020 with the date January 1st, 2021 for hazardous mixtures for consumer use.
  • Transition period: the notifications made before January 2020 will be valid until January 2025 (with the exceptions mentioned above).
  • • The UFI code will not be mandatory to be included in the label for products notified before January 2021, until the end of the transition period: January 2025, where all products will need to have it.
  • • The UFI code will be mandatory on the label for new notifications from January 2021.

Our Chemeter, safety data sheet software allows you to generate the UFI code and display it on the product label, complying with all the requirements of Regulation 2017/542, making easier the process of keeping our product portfolio updated.