UFI/PCN · Distributors
PCN and distributors: what to check before 1 January 2027?
From 1 January 2027, the CLP Regulation will explicitly set out distributors’ obligations for poison centre notifications. Check when an existing supplier notification is sufficient and when information must be updated or a separate notification submitted.
Status checked on 7 November 2026.
Distributors of hazardous mixtures should check before the start of 2027 whether existing poison centre notifications cover their products and countries of sale. Products sold under a distributor’s own brand, relabelling and expansion into other EU Member States require particular attention.
The CLP amendment introduced by Regulation (EU) 2024/2865 explicitly establishes a submission obligation for distributors in these situations under Article 45(1c). The provision applies from 1 January 2027. This date is retained by Regulation (EU) 2025/2439, which postponed certain other CLP requirements.
When does a distributor need to act?
The provision concerns mixtures classified as hazardous on the basis of their health or physical effects where a distributor further distributes them in other Member States, rebrands or relabels them. Classification for environmental hazards alone does not trigger this obligation; the scope and exemptions in Annex VIII must also be considered.
A distributor does not always need to prepare a separate notification. The obligation under Article 45(1c) does not apply if the distributor can demonstrate that the relevant appointed bodies have already received the same information from importers or downstream users. The key is to check whether the product and market are actually covered.
Example: the same cleaner, a new name and a new market
A Slovenian company buys a cleaner from an EU supplier and wants to sell it under its own name in Croatia as well. We recommend obtaining confirmation from the supplier that the notification covers Croatia and the full new trade name. If information is missing, the company can arrange for the supplier’s notification to be updated or make its own submission with the required information. ECHA explains both options.
A UFI on the label is not proof of notification
The unique formula identifier (UFI) links a product to submitted information. Generating a code does not mean that a poison centre notification (PCN) has been submitted. During inspections in Slovenia, the Chemicals Office of the Republic of Slovenia also identified cases where labels carried a generated code without a corresponding notification, or where the UFI did not match the notified information.
What should you prepare now?
For a practical review, we recommend keeping records that link the following information for each product:
- trade names and brands shown on labels;
- UFI codes, current labels and safety data sheets;
- countries where the product is marketed;
- evidence of coverage by an existing notification;
- the person responsible for updates and supplier communication.
These records also make it easier to decide what to do when introducing a new brand or entering an additional market. The 2027 date does not mean existing obligations can be ignored until then: ECHA already emphasises the need for an appropriate flow of information through the supply chain.
Need a review of your notifications?
BiSafe helps with reviewing data, preparing and submitting notifications, and maintaining UFI/PCN records. Send your product list, labels and countries of sale to info@bisafe.si. Find out more on our UFI/PCN services page.
