UFI code: what a unique formula identifier is, which chemical mixtures need one, and where it goes on the label

The law is CLP, Regulation (EC) No 1272/2008Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027The whole regulationClick opens the law on the EU Publications Office., Art. 45Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45Click opens the article on EUR-Lex. and Annex VIII. Annex VIII defines the UFI as “a unique alphanumeric code that unambiguously links the submitted information on the composition of a mixture or a group of mixtures to a specific mixture or group of mixtures” (Annex VIII, Part A, section 5.1). Until 31 December 2026 the duty rests on Annex VIII, Part A, sections 2.1 and 3.1, in the wording of the consolidated text of 1 July 2026. From 1 January 2027 it sits in Art. 45(1b)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1bClick opens the article on EUR-Lex. and Art. 45(1c)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1cClick opens the article on EUR-Lex.. The UFI rules themselves, in section 5 of Part A, read the same in both texts.

A UFI links the label to the poison centre submission

Each EU country appoints a body, often called a poison centre, to receive information on hazardous mixtures so that it can advise when someone is exposed to one (Art. 45(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1Click opens the article on EUR-Lex.). From 1 January 2027 a country may appoint ECHA, the European Chemicals Agency, as that body (Art. 45(1a)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1aClick opens the article on EUR-Lex.). The submission tells the body what the mixture holds. The UFI is the thread between that submission and the pack. A caller reads the code from the label, and the operator finds the matching submission.

ECHA’s training material gives the format. A UFI has 16 characters, upper case letters and digits, in four blocks of four separated by hyphens, and one character is a checksum. ECHA’s own example is VDU1-414F-1003-1862. The letters L, I, O, B and Z are not used. The code holds no information on the composition: ECHA says it can be turned back only into a VAT number and a formulation number (What is a UFI?). That is also why a UFI can stand in for a supplier’s recipe in the supply chain, as step 7 above shows.

Which mixtures need a UFI

The duty covers mixtures “classified as hazardous on the basis of their health or physical effects” (Art. 45(1b)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1bClick opens the article on EUR-Lex.; Annex VIII, Part A, section 3.1). Health hazards are the classes of Part 3 of Annex I: acute toxicity, skin corrosion or irritation, serious eye damage or irritation, respiratory or skin sensitisation, germ cell mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity, aspiration hazard and endocrine disruption for human health. Physical hazards are the classes of Part 2: explosives, flammable gases, aerosols, flammable liquids and solids, oxidising gases, liquids and solids, organic peroxides, corrosive to metals and others. Part 4 (environmental hazards) and Part 5 (hazardous to the ozone layer) are not in the list.

A spray cleaner is often a flammable aerosol, and aerosols are in Part 2. A fragrance oil blend is a mixture, and it is hazardous when its classification puts it in a class of Part 2 or Part 3. The classification is the one in section 2 of the safety data sheet, or your own where you changed the composition. How to classify is in EU CLP Regulation.

Who creates the UFI, and how

The submitter creates the UFI “by electronic means made available by the Agency”, and the assignment is free of charge. ECHA must keep the UFI generator available free of charge on its website (Annex VIII, Part A, sections 5.1 and 6.1). The tool is ECHA’s UFI generator.

• What it asks for. A VAT number and a formulation number. The formulation number is an integer from 0 to 268,435,455 that you assign to a composition. The same VAT number and formulation number always give the same UFI. VAT numbers are entered in their national format, and separators and spaces are ignored (user guide).
• Without a VAT number. The user guide has a route for a company that has no VAT number or chooses not to use it. A company that builds its own generator can get a company key for that case, and ECHA publishes the UFI algorithm in a developers manual (ECHA, Unique Formula Identifier).
• Many products. The generator makes up to 10,000 UFIs in one request, from a list of formulation numbers.
• Saving. The generator does not save what it makes. Store each UFI with the composition it stands for.
• What the VAT number is for. ECHA says it only keeps codes unique, and that no check is made between the VAT number and the submitter. The VAT number may differ from the submitter’s, for example for a private labeller, a toll formulator or a consultant (What is a UFI?).
• One UFI, one composition. ECHA gives two principles: a UFI is assigned to one mixture composition only, and the same UFI is never used for mixtures of different composition. One composition may carry more than one UFI, for example one per product, per country or per label language (Creating and using the UFI).

Where the UFI goes

The UFI is part of the supplemental information of the label (Art. 25(7)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 25, paragraph 7Click opens the article on EUR-Lex.), which sits with the other label elements (Art. 32(4)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 32, paragraph 4Click opens the article on EUR-Lex.). Annex VIII adds the way to print it: “UFI” in capital letters, a colon, then the code, “clearly visible, legible and indelibly marked” (Annex VIII, Part A, section 5.2). The supplier may show it in another way that section 5 permits instead of in the supplemental information (Art. 29(4a)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 29, paragraph 4aClick opens the article on EUR-Lex.).

How big the label and its text must be, and what else sits in the supplemental information, is in CLP label requirements.

The UFI must match a poison centre submission

Before placing a mixture on the market, the submitter gives the appointed body of each EU country where it is placed on the market the information of Part B of Annex VIII. It goes by electronic means, in the XML format ECHA provides free of charge, in the official language of that country unless the country allows another (Annex VIII, Part A, sections 3.1 and 3.3). “The UFI(s) shall be included in the submission” (Annex VIII, Part B, section 1.1). Part B also asks for the classification, the label element codes, the toxicological information, the composition, and details such as the packaging, the colour, the product category and the use (Annex VIII, Part B, sections 1 to 3).

One submission may cover a group of mixtures that share the same classification for health and physical hazards, and a UFI may link to such a group (Annex VIII, Part A, sections 4.1 and 5.1). The group rules and the distributor duty are in CLP label requirements.

The order matters. ECHA’s advice is that the UFI goes on the label at the same time as the submission is made, so that no label carries an “empty” UFI that links to nothing (What is a UFI?).

A new UFI is needed when the composition changes beyond set limits

Annex VIII asks for a new UFI only for a change of composition. It names three conditions: a component that must be indicated is added, substituted or deleted; the concentration of a component moves beyond the range in the original submission; or an exact concentration that was given changes beyond the limits of Table 4 of Part B. For a mixture that follows a standard formula in Part D, or whose composition is given from the safety data sheet, section 4.1 sets its own triggers (Annex VIII, Part A, section 5.1; Part B, section 4.1).

Two changes do not need a new UFI. In a group submission, a change that concerns only the perfumes, or adds a perfume, keeps the UFI. A change that only concerns components already in an interchangeable component group of the submission keeps it too (Annex VIII, Part A, section 5.1).

Other changes need a submission update before you sell the changed mixture, but section 5.1 asks for no new UFI for them: a new classification, a new product identifier, or another change relevant for emergency health response (Annex VIII, Part B, section 4.1). For an exact concentration, Table 4 sets the variation that needs an update: 5% for a component above 25% and up to 100%, 10% above 10% and up to 25%, 20% above 2.5% and up to 10%, and 30% at 2.5% or below. ECHA’s training example applies it to the value: a component at 30% needs an update at 28.5% or below, or at 31.5% or above (Managing your UFI). When the label changes, the timing is in CLP label requirements.

Reusing a UFI for a different composition is prohibited, ECHA wrote on 21 January 2025, after Member States reported cases where the same UFI sat on different compositions. It “makes it difficult for poison centre operators to give accurate information” and “may lead to regulatory non-compliance and enforcement actions” (ECHA, Ensure correct UFI management).

What the 2024 revision changed for the UFI

The UFI itself did not change. Annex VIII, Part A, sections 3 to 6, which hold the submission rules, the UFI and the generator, read the same in the consolidated texts of 1 July 2026 and 1 January 2027. What changed is the circle of duty holders and the text around the UFI. Regulation (EU) 2024/2865Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)The whole regulationClick opens the law on the EU Publications Office. changed it in these steps (Official Journal text).

Until 31 December 2026 a business may already apply the wording of 1 January 2027; the revision allows it (Art. 2(5)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 2, paragraph 5Click opens the article on EUR-Lex.).

The reason for the distributor duty is in the revision’s recital 32. Without a submission from distributors, the appointed bodies lose information when a product moves from one EU country to another, or when a distributor rebrands or relabels it. ECHA’s reading, of 10 December 2024: if no submission exists in a country where the mixture is sold, or the label has new product identifiers, the distributor gives the information to the supplier so it can add it, or submits its own (ECHA, CLP revision defines new role for distributors).

What happens if you do nothing

A mixture that does not comply with CLP may not be placed on the market (Art. 4(10)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 10Click opens the article on EUR-Lex.). Each EU country keeps up official controls to make sure that mixtures are not placed on the market unless “classified, labelled, notified and packaged” in line with CLP (Art. 46(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 46, paragraph 1Click opens the article on EUR-Lex.). Each country also sets its own penalties, which must be “effective, proportionate and dissuasive” (Art. 47Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 47Click opens the article on EUR-Lex.). What market surveillance and customs can do with a product that fails is in CLP label requirements.

Inspectors have looked for exactly this. In a pilot project of the ECHA Forum, inspectors in 18 EU and EEA countries checked 1,597 mixtures. 19% had not been notified to poison centres, and in 15% of the mixtures checked the UFI was missing from the label. The inspectors “initiated numerous enforcement actions” (ECHA, One in five hazardous mixtures not reported to poison centres).

What the law leaves open

• A non-EU seller shipping straight to a consumer. Annex VIII puts the duty on the submitter, who creates the UFI (Annex VIII, Part A, sections 2.1 and 5.1), and CLP’s importer, downstream user and distributor are all established in the EU (Art. 2(17)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 17Click opens the article on EUR-Lex., Art. 2(19)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 19Click opens the article on EUR-Lex., Art. 2(20)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 20Click opens the article on EUR-Lex.). No article names who the submitter is for a parcel that goes from outside the EU straight to a consumer, the same gap as for the EU supplier (see what the law leaves open). Meanwhile, sell a hazardous mixture into the EU through an EU business that submits it and is named on the label.
• Whether a non-EU VAT number works in the generator. ECHA’s user guide shows a VAT field with a help text for each country’s format, and a route without a VAT number. It does not say which countries’ formats the field accepts. The route without a VAT number needs none.
• A distributor that rebrands. Annex VIII says the submitter creates the UFI (Annex VIII, Part A, section 5.1). No article says whether a distributor that relabels may reuse the UFI of the original supplier or must make its own. ECHA’s 2019 training material, which is older than the 2024 revision, says one composition may carry several UFIs. Section 5.1 reads that the submitter creates the UFI, so a distributor that makes its own submission creates its own. The route ECHA describes in its news of 10 December 2024 keeps one submission: the distributor gives the information to the supplier, who adds it to the supplier’s submission.
• The 2028 font rules and the UFI. The new rules speak of “the text on the label”. No article names the UFI among them. A UFI printed on the label is text on the label, so in our reading it follows them from 1 January 2028 (Reg. 2024/2865, Annex I, points 2 and 3).