UNIQUE FORMULA IDENTIFIER

One of the current legislative innovations that regulate the placing of mixtures of chemical products on the market is the unique formula identifier code (UFI).

The unique formula identifier or UFI:

• was released on 22 March 2017, by the Regulation (EU) n. 2017/542, which modifies the previous Regulation (EU) n.2008/1272 (CLP) by adding the Annex VIII, on the harmonized information relating to emergency health response;
• has been further regulated by European Regulation n.2020/11 of 29 October 2019.

UFI is a 16-character alphanumeric code, which must identify mixtures of chemical products, placed on the market and classified as dangerous, due to their health effects or their physical effects.

This code must be on the mixtures label.

In the case of mixtures used at industrial sites, where the product is not required to be accompanied by a label, drafted pursuant to Regulation 1272/2008 (CLP) - typically so-called bulk products - the UFI code may be contained in the Section 1.1. of the Safety Data Sheet (MSDS), in accordance with Annex II (Guide to the compilation of safety data sheets) to Regulation (EU) n.1907/2006 (REACH), as amended by European Regulation n. 2020/878 of 18 June 2020.

The European Regulations n. 2017/542 and n.2020/11, previously mentioned, regulate, among other things, the expected adjustment times for the introduction of the UFI.

Currently, importers and downstream users, who place hazardous mixtures on the market, to which the obligation to have a UFI code applies, must adapt:

• starting from 1 January 2020, in the case of consumer use or professional use;

• starting from 1 January 2024, in the case of industrial use.

However, importers and downstream users who have notified the information relating to hazardous mixtures to a designated Institution (ISS notification - Dangerous Preparations Archive, as required by Legislative Decree N. 65/2003), before the above-mentioned dates, they are not required to comply with the new provisions until 1 January 2025.

All mixtures of chemicals placed on the market by DOLLMAR S.p.A. and classified as hazardous, due to their health effects or physical effects, will be provide the UFI code, as established by the current legislation, according to the relevant adjustment times.

DOLLMAR S.p.A. is organizing to create all the necessary UFI codes, which will also be accompanied by a new notification of the mixtures concerned to ECHA - European Chemical Agency, according to a harmonized data transmission method, available from the designated bodies of all the Member States of the European Union.

Since the large number of products involved in the changes described, it should be noted that DOLLMAR S.p.A. has always regularly notified the dangerous preparations to the Istituto Superiore di Sanità and, therefore, will make use, where possible, especially in a first phase, the possibility of taking advantage of the transitional period, which will end on 1 January 2025.

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