Notification of Hazardous Mixtures under Annex VIII CLP
With the introduction of the harmonised notification procedure according to Annex VIII of the CLP Regulation (EC) No. 1272/2008, the product notification of hazardous mixtures within the EU has been standardised. This replaces or complements the previous national procedures. In Germany, the procedure is implemented through the Chemicals Act (ChemG).
Notification is required for all mixtures classified as hazardous to health or physical safety that are placed on the market – regardless of whether they are intended for consumers, professional users, or industrial use only. Mixtures that are classified solely as hazardous to the environment are not subject to PCN requirements.
Notification Obligation and UFI Code
A core element of each notification is the UFI code (Unique Formula Identifier), which must be printed on the product label. Together with the PCN, the UFI ensures that national poison centres can access complete product data in the event of an emergency.
Who Must Notify?
The responsibility lies with the downstream user (i.e. the manufacturer of the mixture within the EU) or the importer introducing the hazardous mixture into the EU. Contract manufacturers, refillers, and, in some cases, rebranders are also considered liable to notify. In practice, the party responsible in the supply chain must be determined on a case-by-case basis.
The distributor is responsible for ensuring that all products sold have been previously registered for the respective countries of distribution.
We take care of the complete submission process for you upon request – including coordination with upstream suppliers and management of confidential formulation components via the MiM procedure (Mixture in Mixture).
What Must Be Notified?
The notification is submitted via the ECHA Submission Portal or using IUCLID. Required data includes:
- Classification and labelling under CLP
- Full formulation (not just Section 3 of the SDS)
- UFI code
- Toxicological information
- Physical data (e.g. pH value, physical state, colour)
- Product category according to EuPCS (European Product Categorisation System)
- Packaging information
With the support of our compliance consultants, you can ensure that your notification is formally correct, complete, and submitted on time – whether you are a manufacturer, distributor, or importer.