EU Regulation: Unique Formula Identifier (UFI) Soon Mandatory

Unique Formula Identifier (UFI) will soon be required by law on the labels of products classified for health or physical hazards.

The 16-digit code is intended to help Poison Centres to be able to precisely identify the chemicals involved in an incident and provide adequate medical advice.

Product label with Unique Formula Identifier (UFI)
Sample product label with Unique Formula Identifier (UFI) on the bottom right above the barcode

The industrial obligation has been introduced by Annex VIII to the CLP Regulation, which aligns the European Union system of classification, labelling and packaging of chemical substances and mixtures to the Globally Harmonised System (GHS).

The upcoming requirements apply to importers and downstream users who place hazardous mixtures on the market. It will be mandatory to submit notifications with certain product details (trade name, product category, composition, colour, packaging, toxicological information) as well as the UFI, to the appointed bodies such as poison centres.

How to create the UFI code

The Unique Formula Identifier is an alphanumeric code consisting of 16 letters and digits divided by hyphens into 4 sections. The marking has to be clearly visible and legible on the label.

In order to create the UFI, the company’s VAT ID (or ‘company key’) and a mixture-specific formulation number are required. The latter can, for example, be an internal formulation code as long as it is exclusively numeric and lies between 0 and 268,435,255. Otherwise, new numbers must be assigned in the correct format.

With this data you can easily create UFIs via the European Chemicals Agency (ECHA) UFI Generator Tool. Companies without VAT ID can also request a company key there.

Important note: Only products with the very same mixture composition may be labelled with and assigned to the same UFI.

UFI Codes – Post Brexit

REACH registrations submitted by UK-based manufacturers, importers and representatives that were not completed by 31 December 2020 have been terminated.

Any transfer of registrations by a UK company not initiated before 31 December 2020, and accepted by the successor by 31 March 2021, will be revoked.

After 31st December, 2020:

  • All pending UK submissions in REACH-IT will be terminated.
  • No registration numbers will be issued to UK companies.
  • Companies in the UK cannot perform any actions as duty holders in REACH-IT.
  • All registrations held by or returned to UK companies will be revoked gradually in REACH-IT.

REACH stipulates that registrants must be established in the European Union.

When to start with UFI labelling

The CLP Regulation annex will enter into force as from January 1, 2020. Depending on the product, the following transition periods apply for UFI submissions and labelling:

  • by 1 January 2020 for all new mixtures for use by consumers
  • by 1 January 2021 for all new mixtures for professional use
  • by 1 January 2024 for all new mixtures for industrial use
  • by 1 January 2025 for mixtures already on the market and notified under national legislation

Companies should start planning all necessary steps as soon as possible to ensure full compliance before the deadlines.

Existing products already on the market can benefit from a transitional period until 1 January 2025 – if your product data and Safety Data Sheets are registered with the applicable poison centre for each EU member state your product is sold into by January 2020 – otherwise the above deadlines will apply.  This will give more time to create your UFI and add it to your labels.

Once you have created your 16-character alphanumeric UFI codes, these must be printed on to the label of all of your products containing hazardous mixtures in time for the appropriate deadlines.

What are the rules for adding UFI codes to products?

The acronym ‘UFI’ must be in capital letters and be followed by a 16-character alphanumeric code. While no specific requirements have been set, such as for font type or size, the UFI has to be clearly visible and legible on the label of the product.

Given the wide variation in label sizes, and the other label elements competing for space, the UFI should be positioned so that it can be easily located , for example near the hazard pictograms. You must determine how the UFI should be printed in the most effective manner to ensure it is clearly visible.

Products outside the scope of the regulation:

  • Gases under pressure
  • Mixtures for scientific (or product and process oriented) research and development
  • Explosives (unstable explosives)

UK Requirements

It is still unclear whether, and how, chemical laws, including Annex VIII, will be applicable to the UK after its withdrawal from the EU. However, it will continue to apply for sales in all other EU Member States.

Make sure to find out about your obligations and how these could affect your business.

Hibiscus Plc is ready to support you with the production of labels, and authoring of Safety Data Sheets, to allow a smooth transition into compliance for 2020 onwards.


Call us regarding your labelling & SDS requirements on 0113 242 4272‪ ‬