Requirements for documentation of chemical advertising products - UFI, MSDS
When selling products containing chemical ingredients that must be marked with pictograms and composition information, advertising agencies and distributors must take care of several key issues. First of all, a Material Safety Data Sheet (MSDS) must be prepared, which precisely defines the composition of the product and indicates mandatory markings. The second important element is the registration of the product and the assignment of a UFI (Unique Formula Identifier) number, which must be visible on the label.
The UFI number is not always in the same place on the label, but it must always be clearly visible near the product's trade name, brand name, or adjacent to hazard information such as pictograms and safe use directions. The UFI can be directly on the product or on a sticker, but never on the bottom of the package. Both the end user and the distribution intermediary can ask for the UFI number and safety data sheet, so the label must include the details of the company responsible for these documents.
The legal basis for the labeling of such products derives from Regulation 1272/2008/EC of the European Parliament and of the Council of December 16, 2008, which regulates the classification, labeling and packaging of substances and mixtures. This regulation specifies, among other things, the sizes of labels, pictograms and the detailed information that must appear on the label. These regulations apply in the European Economic Area (EEA).
Material Safety Data Sheet (MSDS) - This document must be prepared in the official language of the country where the product is sold. English, although commonly used, will not suffice. Labels must contain data in accordance with the safety data sheet, in the appropriate languages. If a distributor wants to put his data on the label, leaving out the manufacturer, he must prepare his own safety data sheet. Otherwise, the label must contain the data of both the manufacturer and the distributor.
UFI (Unique Formula Identifier) - This is a 16-character code that, as of January 1, 2020, must appear on the labels of new mixtures for consumer use. For new mixtures for professional use, the provision went into effect on January 1, 2021, and for industrial products it applies until January 1, 2024. For mixtures that entered the market before these dates, there is a transition period until January 1, 2025, after which date all mixtures must be assigned a UFI number, and products containing them must be reported to ECHA.
It is importers and distributors placing such products on the market who must ensure that their product containing a mixture subject to UFI regulations is notified to the system in the appropriate languages recognized for the sales area, for example: the German market allows English for UFI notification, but the Austrian market only honors German. The UFI code allows medical services to quickly access product formulation data, facilitating appropriate treatment in health emergencies.
If advertising agencies want to avoid disclosing the manufacturer's data, they must take care of such documentation on their own, based on data from the manufacturer, or use the implementation in companies that support the registration of new UFI numbers for their blends on behalf of the client. Our company offers personalized fragrance tags for cars with the company's logo - we can then put the manufacturer's data on the label, additionally specifying the distributor, and use then ready-made documentation, or prepare everything on separate data, then you should expect additional costs and time for documentation preparation. It is crucial to determine whether MSDS and UFI are to be assigned to the data of the manufacturer, advertising agency or direct customer. Especially when there are more than one agency level for a given product and these options may be several.
As of January 1, 2025, the UFI number is required on all chemical products, including promotional products.
