UFI Codes Explained: What They Are and How to Generate One

There is no GB UFI duty. GB CLP Annex VIII — the provision that introduced UFI codes and poison centre notification for GB — was revoked on 1 January 2024 by the Retained EU Law (Revocation and Reform) Act 2023, Sch. 1 Pt. 2, and nothing was inserted to replace it. GOV.UK states the consequence plainly: "There is no obligation to generate or submit a unique formula identifier (UFI) code in Great Britain" — the same page adds that NPIS will still register a UFI if one has already been generated. What remains on the GB side is a voluntary arrangement rather than nothing at all — see "The GB Position" near the end of this guide.

UFI codes remain mandatory in the EU and in Northern Ireland, where EU CLP — including Annex VIII — applies. This guide covers what a UFI is and how to generate one, for GB sellers who also place products on the EU or NI market.

This covers EU/NI UFI requirements for GB-based sellers exporting into those markets. This is not legal advice.

What Is a UFI Code?

A UFI (Unique Formula Identifier) is a unique code assigned to a specific product formulation. If someone is exposed to your product and contacts a poison centre, the UFI allows the centre to immediately look up the exact composition of the product and provide appropriate medical advice.

The UFI is part of the EU poison centres notification system introduced under Annex VIII of the CLP Regulation ((EC) No 1272/2008). It's designed to replace the previous system where poison centres had to contact manufacturers directly to find out what was in a product — a process that could take hours. In GB, Annex VIII was revoked on 1 January 2024 and this system no longer applies domestically — see GB CLP changes 2026 for the full GB/EU split.

A UFI looks like this: E300-N0V3-C00K-ED92

It is generated with ECHA's UFI generator from a formulation number you assign, optionally combined with your company VAT number. GOV.UK explains what the VAT number is doing: "The use of the VAT number is a means to ensure that 2 different companies using the same formulation number will not produce the same UFI."

When You Need a UFI Code

You need a UFI code if you place a mixture classified as hazardous for health or physical effects, and supplied to consumers, on the EU or Northern Ireland market. You do not need one for products placed only on the GB market — there is no GB UFI duty, and there has not been since Annex VIII was revoked on 1 January 2024.

For UK craft sellers exporting into the EU or NI, the types of product likely to be affected include:

• Scented candles classified for health hazards (skin sensitisation, eye irritation)
• Wax melts with the same classifications
• Reed diffusers and room sprays (often classified for more severe health hazards due to higher fragrance concentrations)

If you sell only within Great Britain, none of the UFI or notification sections below creates a duty for you — but read "The GB Position" near the end, because a voluntary NPIS arrangement does exist. If you sell into the EU or NI as well, read on. Our GB CLP changes guide explains the full GB/EU divergence.

How UFI Code Generation Works

UFI codes are produced by ECHA's UFI generator, which is free to use. You need:

1. A formulation number — a number you assign to each unique formulation. Formulation 1, formulation 2, etc. Each different recipe gets a different number.

2. Your company VAT number — optional. Its only job is to stop two different companies producing the same UFI from the same formulation number. GOV.UK is explicit that a company without an EU VAT number can still generate one: it can "select the box which states: ‘By ticking this box, I declare that the company does not have a VAT number or chose not to use it to generate a UFI.’" That covers most craft sellers below the £90,000 registration threshold.

The generator turns these into your UFI — what Annex VIII describes as "a unique alphanumeric code". The same inputs always produce the same UFI, so you can regenerate it if needed.

One UFI per formulation: If you change the recipe, you need a new formulation number and therefore a new UFI. If you sell the same recipe under different brand names, they share the same UFI.

Where the UFI Goes on Your Label (EU/NI Only)

For products placed on the EU or NI market, the UFI must appear on the CLP label. It can be placed:

• In the supplemental information section of the label
• Near the other CLP label elements
• Prefixed with "UFI:" followed by the code (e.g., "UFI: E300-N0V3-C00K-ED92")

Annex VIII requires the UFI to be "clearly visible, legible and indelibly marked". This requirement does not apply to a GB-only label.

The Poison Centre Notification (EU/NI Only)

For EU and NI sales, generating the UFI is only half the process. You must also submit a notification to the relevant poison centre appointed body containing:

• The UFI
• Your complete formulation (exact ingredients and concentrations)
• Product identification (trade name, packaging description)
• Classification and labelling information
• Contact details for emergency enquiries

For Northern Ireland, GOV.UK names the route precisely — and it is not the route most people assume:

"NPIS does not have access to the European Chemicals Agency (ECHA) poison centre notification (PCN). Therefore, submissions for NI must be provided in the form of a PCN and sent directly to NPIS Birmingham as the appointed body."

So an NI submission uses the ECHA PCN format — a dossier produced in, or imported into, ECHA's IUCLID platform — but goes by email to NPIS Birmingham rather than to ECHA. GOV.UK adds: "You must also include a UFI in the submission of information and on the label or, in some cases, the packaging of the products that contain a hazardous mixture."

For an EU member state, check the notification requirements of each EU market you actually sell into. Do not assume the NI route above carries across, and do not assume a single portal covers every member state.

The GB Position: Voluntary, Not Nothing

There is no mandatory GB notification, because there is no GB UFI duty. But "no duty" is not the same as "nothing exists", and this is where GB-only sellers are most often mis-advised in both directions.

GOV.UK sets out a voluntary GB arrangement:

"GB-based importers and downstream users, and NI-based downstream users directly supplying the GB market with qualifying Northern Ireland goods (QNIGs), are encouraged to voluntarily submit information relating to emergency health response, and preventative measures on hazardous mixtures placed on the GB market, to NPIS using a safety data sheet (SDS)."

And on the UFI specifically:

"There is no obligation to generate or submit a unique formula identifier (UFI) code in Great Britain but the NPIS will register your product with its associated UFI if one has already been generated."

HSE puts it in the same terms, directing GB-based importers and downstream users to "the arrangements for submitting information to the UK National Poisons Information Service (NPIS) known as the National poison Centre". A maker buying in fragrance oils and wax and blending them is routinely a downstream user under GB CLP, so this is squarely aimed at this audience — but it is an arrangement to be aware of, not a duty to discharge.

Practical Considerations for EU/NI Exporters

Reformulations trigger new UFIs. If you change a fragrance oil, adjust a concentration, or switch any ingredient, the formulation is different and needs a new UFI. This is one reason to avoid constant reformulation — each change adds administrative overhead.

Multi-fragrance ranges. Each fragrance variant is typically a separate formulation requiring its own UFI, even if the base wax and fragrance load are identical. Different fragrance oils have different chemical compositions.

Record keeping. Maintain a register mapping each UFI to its formulation details. If a poison centre contacts you, you need to be able to quickly identify which exact recipe corresponds to a given UFI.

Cost: Generating a UFI is free — it's an algorithmic calculation, not a paid service. The cost is in the time and administration of maintaining formulation records and submitting notifications.

GB-only sellers: none of the above is a duty for you — no UFI, no mandatory notification. The voluntary NPIS route described above is the only GB-side thing here, and it is optional. See our complete CLP labels guide and step-by-step CLP labelling guide for what your GB label actually needs.

Sources

• Annex VIII to Regulation (EC) No 1272/2008, inserted by Commission Regulation (EU) 2017/542 — the operative EU text. The wording quoted above is at Part A, sections 5.1 and 5.2.
• Annex VIII on legislation.gov.uk — the GB record. It now shows the annex revoked with the text removed, which is why the quotations above cite the EU source.
• Retained EU Law (Revocation and Reform) Act 2023, Sch. 1 Pt. 2 — the revoking instrument
• HSE — The GB CLP Regulation
• HSE — CLP Labelling and Packaging Requirements
• GOV.UK (DHSC) — Submitting chemicals information to the National Poisons Information Service (the GB voluntary route, the NI PCN route, and UFI generation without a VAT number)