Annex VIII to the CLP regulations (EU “flavor” of GHS) was adopted in March 2017 (and amended in October 2019) to require companies that market products in the EU to submit hazard information about their products in a new, structured XML format. The compliance dates vary depending upon the use type of the product:
The information in the submissions includes some of the information currently contained in sections 1, 2, 3, 9, and 11 of the EU SDS format, as well as some new information including:
- A UFI Code which is a unique identifier for your product
- A Product Characterization Code and Description of your product
- A Use Type for your product – either Consumer, Professional, and/or Industrial
- Packaging Types and Sizes
- Some physical property information, including physical state, and pH (which already exist on the SDS) and Colour and pH concentration (which do not currently exist in Section 9 of the SDS)
The UFI Code is specific to a given product and mixture composition, so a new one must be created whenever the composition of a product changes (outside of certain limits) or when the hazard information is updated. The UFI code is a 16 character code separated by hyphens in 4 blocks, like:
The UFI Code must be included in the XML submission as well as displayed on your product labels. This allows easy access to the proper product hazard information by the Poison Control Centre(s) in case a poisoning occurs:
The UFI Code will be automatically generated by ProductVision from the company VAT number and a unique, sequential formula code and stored with the product as a formula property. The UFI does not need to be included on the SDS for Consumer or Professional products but should be included in Section 1.1 of the SDS for Industrial products.
The Product Characterization Code and Description is a standardized product category based upon the main intended use selected from the European Product Categorization System (EuPCS) and looks like:
This code has up to 250 potential values. In ProductVision these values are contained in the validation table in a new formula validated property.
The submission requirements will be programmed into ProductVision in a new “EU Poison Module” as part of ProductVision version 5.3 with initial release scheduled for 2nd quarter 2020. For more information about the Annex VIII and the EU Poison submission requirements, see https://poisoncentres.echa.europa.eu/
The ProductVision® product development software is a product lifecycle management (PLM) system that manages all aspects of the product development process. Suitable for industries including paint & coatings, personal care and food & beverage, ProductVision’s comprehensive list of modules includes Formula Management, Regulatory, GHS, Project Management, Document Management, Ingredient Labelling, Guidelines & Restrictions, Sample Tracking, Testing and Workflow. We have your complete development process covered no matter what your industry.