SDS Section 1: Mixture Product Identifier & UFI Code

MSDS-Europe – Safety Data Sheet Knowledge Base – SDS Section 1: Product identifier for mixtures and the UFI

Our clients often ask what exactly must be stated—and how—in SDS Section 1 as the mixture’s product identifier, and when the UFI (Unique Formula Identifier) and the Poison Centre Notification (PCN) are mandatory.

In our experience, this is where most errors occur—so we dedicate a separate, detailed article to this topic, so our clients can access the most important information in one place.

SDS Section 1: Product identifier for mixtures

1. Legal background in brief

The requirements for the product identifier of mixtures are primarily defined by two pieces of legislation:

the CLP Regulation (Regulation (EC) No 1272/2008), in particular Article 18 and Annex VIII (UFI, PCN),
the REACH Regulation (Regulation (EC) No 1907/2006), Annex II, which lays down the content and format requirements for the safety data sheet (SDS).

Article 18(3) of the CLP Regulation states that a mixture’s product identifier must include, among other things:

the mixture’s trade name or designation,
and—on the label—the names of certain hazardous ingredients (those responsible for the health hazards), where required.

In the SDS, the product identifier must be:

stated exactly as on the label, and
provided in the official language(s) of the Member State(s) where the mixture is placed on the market (unless that Member State provides otherwise). (See also: Language of the Safety Data Sheet in the EU.)

2. What does “product identifier” mean for a mixture?

For mixtures, the purpose of the product identifier is to enable the user to clearly identify the product—in the SDS, on the label, and throughout the supply chain.

A mixture’s product identifier typically consists of the following elements:

Trade name / designation

E.g., “AlkaClean 10 – alkaline cleaning concentrate”

(Optional) internal identifier / article number

E.g., “AC10-KONC”

UFI (if available and shown in the SDS)
(Optional) short function / intended use

E.g., “Cleaning agent for stainless steel surfaces for industrial use.”

3. Product identifier in SDS subsection 1.1 – practical guidance

In SDS subsection 1.1, the product identifier must be provided in line with CLP Article 18.

In practice, a well-structured subsection 1.1 may look like this:

Product identifier / Trade name:

“AlkaClean 10 – alkaline cleaning concentrate”

Internal identifier:

“AC10-KONC” (not mandatory, but recommended)

UFI:

“UFI: YV9K-3J9A-G209-XXXX” (if applicable)

Intended use – short description (optional):

“For industrial use only.”

EuPCS and Identified Uses in the Safety Data Sheet and in PCN Notifications

A few important points:

the trade name must appear identically in the SDS and on the label,
if the product is placed on the market in multiple Member States, the SDS must be provided in the official language of each Member State,
for a multilingual SDS, the trade name is usually the same, but descriptive parts should be translated into the local language.

4. UFI – the role of the unique formula identifier

4.1. What is the UFI?

The UFI (Unique Formula Identifier) is a 16-character alphanumeric code with the “UFI” prefix, divided into four blocks (e.g., UFI: YV9K-3J9A-G209-XXXX).

Its purpose is to:

create an unambiguous link between the mixture and the composition information submitted in the Poison Centre Notification (PCN),
enable poison centres to identify the product quickly in an emergency,
while still protecting the manufacturer’s trade secrets (exact composition): the user does not need to know the formulation details—knowing the UFI is sufficient.

The UFI can be created using ECHA’s online UFI generator; in practice, UFI creation and PCN compliance are typically managed together as part of PCN notification services and UFI management.

4.2. When is it mandatory to create a UFI?

A UFI must be created and a Poison Centre Notification (PCN) must be submitted for any mixture that:

is placed on the market in the EU/EEA, and
is classified as hazardous based on physical and/or health hazards (under the CLP Regulation).

5. UFI on the label and in the SDS

5.1. UFI on the label

As a general rule, the UFI must be shown on the mixture’s label, clearly visible and indelible. (For practical labelling aspects, see: CLP labelling in practice.)

In practice, it is often placed:

near the hazard pictograms and the H and P statements,
or at the bottom of the label, presented separately.

It is important that the UFI shown on the label matches the UFI recorded in the PCN notification.

5.2. UFI in the SDS – when is it mandatory and when is it optional?

Including the UFI in the SDS is:

not mandatory in general,
if it is included, it should be stated in SDS subsection 1.1,
for non-packaged (bulk) mixtures, the UFI must be provided in the SDS or in a label copy as referred to in Article 29(3),
for a packaged mixture intended for industrial use, the UFI may appear only in the SDS instead of on the label (or in both places).

Practical recommendation:

If a mixture has a UFI and a PCN notification has been submitted, it is advisable to state the UFI both on the label and in SDS subsection 1.1—this:

helps the user and supply-chain actors,
reduces the risk of errors (mismatch between SDS and label),
supports rapid identification in an emergency.

6. Same mixture, multiple UFIs – is it allowed?

According to Annex VIII and ECHA guidance:

one UFI is generally linked to one mixture composition. However, it is permitted that the same UFI covers multiple mixtures with slightly different compositions if the differences remain within the concentration ranges specified in Annex VIII (e.g., interchangeable component groups (ICG), standard formulations),
it is also possible for one mixture to have multiple UFIs (e.g., different trade names or target markets).

ECHA guidance strongly recommends that:

within a given SDS, ideally only one UFI should be provided—especially when the same SDS is used in multiple Member States.

7. Practical tips for managing the product identifier and the UFI

7.1. Consistent product identifier between SDS and label

check that exactly the same trade name is shown in SDS subsection 1.1 and on the CLP label,
aim to ensure that the internal article number, UFI, and other identifiers appear consistently across all documents,
for products intended for multilingual markets, aligning the CLP label draft and the language-specific SDS versions is especially important.

7.2. Changing composition, new UFI, revised SDS

If the mixture’s composition changes such that:

it does not exceed the allowable ranges under Annex VIII, then a new UFI is generally not required, but a PCN update and an SDS update may still be necessary (e.g., change in hazard classification).
the change is significant (new hazardous component, substantial concentration shift, new hazard class), then a new UFI, a new PCN notification, and an updated SDS are required.

7.3. Multiple countries, multiple languages – one consistent UFI

If the same mixture is placed on the market in multiple countries:

it is advisable to use the same UFI in every country,
the SDS must be translated into the language of each country,
the UFI remains unchanged, while the text (e.g., product description, intended use) is provided in the local language.

Related services

The combination of the CLP Regulation, REACH Annex II, and Annex VIII (UFI, PCN) is a major challenge for many companies.

Typical tasks we support:

SDS compilation: preparing a safety data sheet in line with the latest REACH/CLP requirements, with a correct product identifier and—if needed—UFI inclusion.

Safety data sheet translation: professional translation of existing SDSs into multiple European languages, taking local legal requirements into account.

SDS updating: updating old or outdated SDSs in line with the latest relevant legislation.

CLP label draft creation: preparing a CLP-compliant label layout with correct placement of the product identifier, UFI, pictograms and statements.

PCN notification & UFI management: UFI generation, PCN dossier preparation and submission via the ECHA Submission Portal.

Quick questions and answers

Is it enough to identify the mixture in the SDS only with an article number?

No. Under the CLP and REACH Regulations, a clear trade name or designation is always required. An internal article number or code can only be supplementary information—it is not sufficient as a standalone product identifier.

Do we have to use the same name in the SDS and on the label?

Yes. The trade name used on the label must match the product identifier stated in the SDS. Using two different names can cause confusion and complaints—and may also lead to enforcement issues and problems for poison centres.

When is it mandatory to include the UFI in the SDS?

It is mandatory to include the UFI:

for non-packaged (bulk) mixtures, in the SDS (or in a copy of the label elements),
for a packaged mixture intended for industrial use, if the supplier decides to provide the UFI in the SDS instead of on the label.

In other cases, the UFI should primarily be shown on the label; including it in the SDS is strongly recommended, but not mandatory in all cases.

Do all mixtures classified as hazardous require a UFI and PCN?

No. In principle, the Poison Centre Notification (PCN) and the UFI are mandatory for mixtures classified as hazardous based on physical and/or health hazards. If a mixture is hazardous only due to environmental hazards, this is a more specific case; it is advisable to check the requirements in the relevant Member State or consult an expert.

What should we do if the mixture’s composition changes?

That depends on the extent of the change:

If the modification remains within the allowable concentration ranges under Annex VIII, in many cases a PCN update and an SDS update are sufficient.
If the change is significant (new hazardous component, material shift in concentration, new hazard class), a new UFI must be generated, a new PCN notification must be submitted, and both the SDS and the label must be updated.

We need multilingual SDSs for the same mixture. Can we use the same UFI everywhere?

Yes—and this is usually the best approach. The UFI for a mixture can be the same across the EU/EEA; SDS language versions differ only in the text (translation), while the UFI remains unchanged. This greatly simplifies PCN management and emergency communication.

Do you have more questions?

Contact our Customer Service, or ask our expert a question online.

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