Category: Advice / Law and CLP | Reading time: 10 minutes
Introduction
You've done the CLP classification. The result: H317 - your candle is classified as sensitizing. Pictograms, the WARNING signal word, H and P statements appear on the label. But that's not all - now you also need to generate a UFI code and notify the poison centers in every EU country where you sell your product.
Sounds complicated? At first glance, yes. But when you break it down into steps, it turns out to be a procedure, not rocket science. In this article, we'll guide you through the entire process: what UFI is, when you need it, what a PCN notification looks like, and how much it costs.
1. What is a UFI code?
UFI (Unique Formula Identifier) is a 16-character alphanumeric code in the format XXXX-XXXX-XXXX-XXXX, which is unique to a specific formulation of your product. For example, it looks like this: UFI: E4GV-R56A-QJ3V-C2F6.
The purpose of UFI is simple: if someone is poisoned by your product (or suspects poisoning) and calls a poison center, the doctor provides the UFI code from the label - and immediately receives the full composition of the mixture to know how to treat it. Without UFI, the doctor has to guess what's inside.
Key UFI rules:
- One UFI = one formulation. If you change the composition (different oil, different proportion) - new UFI.
- The same UFI for different packaging of the same product (e.g., 100g and 200g candles with identical composition = same UFI).
- UFI must be on the CLP label and in section 1.1 of the Safety Data Sheet.
- You generate UFI yourself - for free, on the ECHA website.
2. When UFI is mandatory - and when it is not
UFI IS mandatory when:
Your candle is classified as hazardous due to health or physical properties. Most commonly:
- H317 - May cause an allergic skin reaction
- H302 - Harmful if swallowed
- H319 - Causes serious eye irritation (if classified as a mixture)
UFI is NOT mandatory when:
- The candle is not classified as hazardous → no UFI
- The candle has only EUH208 → no UFI
- The candle is classified only environmentally (e.g., H410, H411, H412) → no UFI
Practical test: Is there a GHS07 (exclamation mark) or GHS08 (health hazard) pictogram on your CLP label due to a health hazard? If so - you need UFI. If there is only GHS09 (environment) or no pictograms - you don't need it.
3. How to generate a UFI code - step by step
Generating a UFI is free and takes 2 minutes:
- Go to the UFI generator - address: ufi.echa.europa.eu
- Provide your company's VAT number (Tax ID) or internal form number
- Provide the product form number - your internal formulation identifier (e.g., "CW-VANILLA-8%")
- Click "Generate" - you will receive a XXXX-XXXX-XXXX-XXXX code
- Save it - you will place it on the CLP label and in section 1.1 of the SDS
Important: UFI itself is just a code. For it to make sense, you must link it to the full composition - which is done in the PCN notification.
4. PCN Notification - what it is
PCN (Poison Centres Notification) is the formal notification of your mixture's composition to the poison center system managed by ECHA. It includes: product identification, full composition with exact concentrations, classification, toxicological information, and notifier details.
Key rules:
- Separate notification per EU country where you sell
- .i6z format - prepared in IUCLID and submitted via the ECHA Submission portal
- BEFORE placing on the market - not after the fact
- Update upon composition change - formulation change = new UFI + new notification
5. Three PCN notification paths
Path A: Independently
Free IUCLID software + ECHA Submission portal. Realistically: 1-2 days of learning the first time.
Cost: 0 PLN | Time: 1-2 days learning + 2-4h per notification | For whom: technical people with many fragrances
Path B: Through an external chemist
A company specializing in chemical documentation does everything for you.
Cost: 300-600 PLN per fragrance per country | Time: 3-14 days | For whom: anyone without technical knowledge
Path C: SDS from TopWosk + our partner Chemtra Consulting
If you buy oils from TopWosk and have our Safety Data Sheets:
- You buy oil from TopWosk - you download the ready SDS for your concentration
- You contact Chemtra - our partner specializing in PCN notifications
- Chemtra prepares the notification based on the SDS from TopWosk and the .i6z file they receive from us
- You receive the UFI code and confirmation of notification
Cost: 125 PLN per fragrance (Poland) | Time: a few business days | Condition: SDS from TopWosk
| Independently | External chemist | TopWosk + Chemtra | |
|---|---|---|---|
| Cost | 0 PLN | 300-600 PLN | 125 PLN |
| Time | 1-2 days learning + 2-4h | 3-14 days | A few business days |
| Required knowledge | IUCLID, .i6z format | None | None |
| Condition | - | - | SDS from TopWosk |
6. Where to place the UFI
On the CLP label: UFI code preceded by the prefix "UFI:" - e.g., UFI: E4GV-R56A-QJ3V-C2F6. Legible, durable, on the packaging (not on the wax).
In the Safety Data Sheet: section 1.1, below the product identifier.
What NOT to do: do not print the UFI on the wax itself, do not hide it among barcodes, do not use one UFI for different formulations.
7. When do you need a NEW UFI?
New UFI required:
- Change in oil concentration (e.g., 8% → 10%)
- Change in fragrance oil (even to a different version of the same fragrance)
- Change in wax (e.g., soy → soy-rapeseed blend)
- Addition of a new classified ingredient
New UFI NOT required:
- Change in packaging size with the same composition
- Change in product name with the same composition
- Change in wax supplier, if CAS and classification are identical
- Minor production fluctuations (±0.5%) without classification change
8. Frequently Asked Questions
"My candle only has EUH208. Do I need UFI?" - No. EUH208 is supplementary information, not a health hazard classification.
"I only sell in Poland. Do I need to notify other countries?" - No. You only notify countries where you actually sell.
"How much does it cost to generate UFI itself?" - 0 PLN. The ECHA generator is free. The cost is only for preparing and submitting the PCN notification.
"What happens if I sell a candle with H317 without UFI and PCN?" - You violate Article 45 of the CLP regulation. Consequences: penalty from the Trade Inspection, product withdrawal, blocking of offers on platforms.
"Does TopWosk do the PCN notification for me?" - Not directly. We prepare the SDS and the .i6z file. The notification is carried out by our partner - Chemtra - on your behalf, for 125 PLN. You contact them with our SDS.
Summary
UFI and PCN are an organized process: generate the code → prepare the notification → send to ECHA → place the UFI on the label. And if your candle is not classified as health hazardous - you don't need any of this.
Four things to remember:
- UFI is only mandatory for health/physical hazards - EUH208 and environmental classification DO NOT require UFI
- Generating UFI is free - only the PCN notification costs money
- Change in formulation = new UFI - even a change in oil concentration
- Notification BEFORE sales - not after the fact
Do you buy oils from TopWosk? You get ready SDS in three concentrations. If your candle requires a PCN notification - contact our partner, Chemtra. Based on the SDS from TopWosk, they will prepare the notification for 125 PLN. And if you choose a concentration below the classification threshold - you avoid the entire process. We provide thresholds for each oil. Check out our fragrance oils →