Regulation (EU) No 2017/542 brought amendments (Annex VIII) to the CLP-Regulation that will lead to additional labelling requirements of mixtures, to include a defined “Unique Formula Identifier” (UFI). There will also be considerable changes to your existing duties for Poison Center Notifications (PCN) in European countries according to Article 45.
Considerable effort will likely be necessary from industry to address these new requirements, especially as the deadlines for consumer use products (1 January 2020), professional use products (1 January 2021) and industrial products (1 January 2024) are approaching fast.
To ensure compliance for your products, it is strongly advisable to address this topic soon, especially if your product portfolio is sizeable or you need to address aspects of trade secrets/confidential business information protection in a non-trivial supply chain. The final XML-format and tools for UFI generation and central Poison Center Notification are expected to be available from ECHA by the end of 2017 (current draft versions can be found here)
Also bear in mind that having your required notifications performed now in the current format can delay your requirement for central notification up until 1 January 2025.
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