Poison Centre Notification (PCN): Which Products Need It and How the ECHA Portal Works

The question usually arrives as an email from a French or German stockist: "Can you send us the UFI for these?" If you make candles, wax melts or reed diffusers and have never heard of a UFI, that email can stall an order for weeks. The UFI is the visible end of a poison centre notification, or PCN, and it is one of the few EU rules where home fragrance and cosmetics go completely separate ways.

I will walk through which products need a PCN, why cosmetics never do, who is legally responsible for filing, how the ECHA submission portal works in practice, and what changes for Great Britain, Northern Ireland and, from January 2027, for EU distributors.

What a PCN is actually for

Picture a toddler who drinks from a reed diffuser bottle. The parent rings a poison centre, reads the code from the label, and the operator pulls up the exact formula, its hazards and its pH. That is the whole point. Article 45 and Annex VIII of the CLP Regulation require importers and downstream users placing hazardous mixtures on the market to send that information to an appointed body in each member state, in one harmonised format, before the product goes on sale. The current text of Annex VIII was set by Regulation (EU) 2020/1677, and it has applied to consumer and professional products since 1 January 2021 and to industrial-use mixtures since 1 January 2024. The grace period for products notified under the old national systems ended on 1 January 2025, so every in-scope product on the EU market now needs an Annex VIII notification.

Which products need a poison centre notification

The test is simple to state: is the mixture classified as hazardous for health effects or physical effects under CLP? If yes, and you place it on the EU market, it needs a PCN. If the only classification is for the aquatic environment, it does not. Annex VIII also leaves out mixtures for scientific research and development and mixtures classified only as gases under pressure or explosives, none of which matter much to a fragrance brand.

In practice, the label tells you most of what you need. A skin sensitiser (H317), eye irritant (H319), aspiration hazard (H304) or flammable liquid (H226 or H225) puts the product in scope. A label showing only EUH208 ("Contains linalool. May produce an allergic reaction.") with an aquatic pictogram does not, because EUH208 is supplemental information rather than a classification.

Product	Typical classification	PCN needed for EU sale?
Reed diffuser liquid	Often skin sensitiser, eye irritant, aspiration toxicity	Yes, in most cases
Wax melt with a high fragrance load	Often skin sensitiser plus aquatic hazard	Yes, if classified as a skin sensitiser
Scented candle	Varies: skin sensitiser, or only EUH208 and aquatic hazard	Yes only if it has a health or physical classification
Alcohol-based room spray	Flammable liquid, sometimes eye irritant or sensitiser	Yes
Aerosol room spray	Aerosol (a physical hazard class)	Yes
Water-based room spray, unclassified	None	No
Multi-surface cleaning spray	Often eye irritant or skin irritant	Yes, if classified
Fragrance oil sold to other makers	Usually skin sensitiser, often more	Yes, if you are the EU importer or formulator placing it on the market
Finished cosmetic (perfume oil, soap, body mist)	Not classified under CLP	No, cosmetics are outside CLP

Why finished cosmetics are always exempt

CLP Article 1(5)(c) says the regulation does not apply to cosmetic products in their finished state intended for the final user. No CLP classification means no PCN and no UFI. A perfume oil and a reed diffuser can share the same fragrance at the same strength, and only the diffuser needs a notification. The cosmetic is covered by the Cosmetics Regulation instead, with a CPSR and a CPNP notification in the EU or SCPN in Great Britain.

That split is why a brand selling both body care and home fragrance ends up running two compliance tracks side by side. If you are not sure which side a product falls on, our guide to TRA versus CPSR sets out how to decide. Be careful with the raw materials, though: the fragrance oil you buy in bulk is a classified mixture, and its supplier has its own CLP duties.

The UFI code: what it is and where it goes

The unique formula identifier is a 16 character code in four blocks separated by hyphens. You create it for free with ECHA's UFI generator from two inputs: your company VAT number (or a company key if you have no VAT number or prefer not to use it) and a formulation number you assign to the mixture. Products with exactly the same composition can share one UFI, even across different brand names or bottle sizes. A different scent is a different composition, so it normally needs its own.

On the label it must read "UFI:" in capitals with a colon, followed by the code, clearly visible, legible and indelible. It sits with the other label elements, or on the inner packaging next to them. Only when the inner pack is too small or awkwardly shaped can it move to the outer packaging. On a wax melt clamshell that already carries a CLP panel, that is another line of text to fit, so add it to the artwork before you print, not after.

Who has to submit, and where non-EU brands stand

The duty holders are importers and downstream users who place the mixture on the EU market. A downstream user here includes the formulator who makes the product in the EU. ECHA's page on who has obligations is blunt about the rest: the obligation lies with the EU legal entity, and a non-EU supplier cannot replace it.

So if you are a UK candle maker shipping to a distributor in Lyon, the distributor is the importer and the notification is its job. It cannot do that job without your formula, classification and SDS. Many suppliers are reluctant to hand over full formulas, which is why ECHA and national authorities describe a second route: the non-EU supplier makes a voluntary submission through an EU-based legal entity, then passes its UFI to the importer, who references it in its own notification without seeing the full recipe.

A change is coming. Under Regulation (EU) 2024/2865, from 1 January 2027 distributors also become duty holders when they supply a hazardous mixture into another member state, or rebrand or relabel it, unless the appointed body already holds the same information. A German wholesaler that buys your diffusers and sells them on into Austria will want proof that a notification exists for Austria. The same amendment adds a duty to update the notification for any other change relevant to emergency response, such as new packaging or new contact details.

What goes into the dossier

• Product identity. Every trade name and variant name as it appears on the label, the UFI, and the submitter's contact details.
• Hazard and label information. The classification, the hazard and precautionary statement codes, and the toxicological information from section 11 of the SDS.
• Product details. Colour, physical state, pH where relevant, packaging type and size, intended use and the EU product category (EuPCS).
• Composition. Classified components at 0.1% or more and unclassified components at 1% or more, as exact figures or within the permitted concentration ranges. The most hazardous components, such as Acute Tox 1 to 3 or Skin Corr 1, need exact figures or narrow ranges.

Fragrance is where home fragrance brands get stuck, so it is worth being precise. The generic identifier "perfumes" can only be used for components that are not classified for any health hazard and that total 5% or less of the mixture. That rarely helps a diffuser at 20% fragrance. The more useful route is the mixture-in-mixture approach: if your fragrance oil supplier has notified the oil and given you its UFI, you can declare the oil by name, concentration and UFI rather than listing every constituent. Ask for that UFI when you buy the oil. It saves a great deal of work later.

There is also a group submission option for products that share the same classification and differ only in their perfumes, provided the differing perfumes total no more than 5%. That suits a low-fragrance room spray range far better than diffusers or melts.

How the ECHA submission portal works

For EU countries you file through the ECHA submission portal, which you reach with an ECHA account. There are three ways to build the dossier:

• IUCLID Cloud. Prepare the dossier online and submit straight to the portal. For a small brand this is usually the simplest option.
• IUCLID desktop or server. Build it offline and upload the dossier to the portal.
• System-to-system. For companies filing in volume from their own software.

The portal runs validation checks when you submit, and you can run the same checks in IUCLID beforehand. Once a dossier passes, it goes to the appointed body of each country you selected. National fees, acceptance rules and language requirements are set by each member state, and ECHA keeps an overview of them on its PCN preparation page. By default the dossier must be in the official language of each country you sell in, unless that country accepts another language.

Great Britain and Northern Ireland

Great Britain swapped EU CLP for GB CLP on 1 January 2021 and did not copy the EU poison centre scheme. According to GOV.UK guidance on the National Poisons Information Service, GB importers and downstream users are encouraged, but not required, to email an SDS to NPIS at sds.npis@nhs.net. There is no obligation to create a UFI for GB, although NPIS will record one if you already have it.

Northern Ireland is different. EU CLP, including Annex VIII, still applies there, and NPIS Birmingham is the appointed body. NPIS has no access to the ECHA portal, so NI submissions must be a PCN format dossier exported from IUCLID as an .i6z file and emailed to NPIS. An NI stockist that buys from a GB business counts as an importer under EU CLP and carries that duty. If you sell direct to Northern Ireland consumers from Great Britain, check the position with NPIS or HSENI before you ship.

A worked example: three diffuser scents, three markets

Take a small UK brand with a 100 ml reed diffuser in Fig, Amber and Linen. Each liquid carries about 20% fragrance in a solvent base and is classified as a skin sensitiser and an aspiration hazard. They want to sell through a distributor in France, a stockist in Germany and a gift shop in Belfast.

• Scope. All three are classified for health hazards, so all three need a PCN in each market.
• UFIs. The fragrances differ by far more than 5%, so a group submission is out. That means three mixtures, three formulation numbers and three UFIs.
• Who files. The French and German businesses are the EU importers and file through the ECHA portal in French and German. If the brand does not want to share full formulas, it makes voluntary submissions through an EU-based entity and gives the importers its UFIs. The Belfast shop is an importer under EU CLP and sends the .i6z dossiers to NPIS by email.
• Label. One label design per scent, each with its own "UFI:" line next to the CLP panel.
• Later changes. If the brand swaps the fig fragrance for a new supplier's version, that changes a notifiable component. The fig diffuser then needs a new UFI and an updated submission before the new stock ships.

Quick PCN checklist

• Check every SDS for a health or physical hazard classification.
• Take finished cosmetics and aquatic-only products off the list.
• Agree in writing who the duty holder is in each EU country and in Northern Ireland.
• Ask fragrance oil suppliers for their UFIs.
• Generate one UFI per distinct mixture and add it to the artwork.
• Submit before the goods are placed on the market, not after the first sale.
• Keep the submission reports with the SDS and technical file, and update after any change.

How PCN fits with your TRA, label and SDS

The PCN is built from the same data as the rest of your home fragrance paperwork. The toxicological risk assessment works out the hazards, the CLP classification decides whether a PCN is needed and what the label says, the safety data sheet carries that classification down the supply chain, and the PCN reports it to poison centres. When those documents come from different places, the classification on the SDS and the one in the notification often drift apart. That mismatch is exactly what an enforcement officer or a careful distributor will spot. Our guides to risk assessment for candles and wax melts and room sprays and reed diffusers cover the earlier steps.

Phoenix can check which of your products need a notification, generate the UFI codes and prepare and submit the dossiers through our ECHA Poison Centre Notification service, alongside the TRA, SDS and CLP label design for the same range.

Common mistakes we see

• Notifying cosmetics. Finished cosmetics are outside CLP. Their route is CPNP or SCPN, not the ECHA portal.
• Treating every scent as one product. Different fragrances mean different compositions and usually different UFIs.
• Shipping before agreeing who files. A distributor who finds out after delivery may refuse to sell the stock.
• Assuming Northern Ireland follows GB. It follows EU CLP, and the dossier goes to NPIS rather than through ECHA.
• Forgetting updates. A new fragrance supplier, a new classification or a new trade name all require an update before the changed product goes on sale.

Related reading on the Phoenix blog

• TRA vs CPSR: which safety assessment does your product need?
• Toxicological risk assessment for candles and wax melts
• Room sprays and reed diffusers: why they need a TRA, not a CPSR
• Do cosmetics need an SDS? When a safety data sheet is required

Myths we hear

• My body oil contains the same fragrance as my diffuser, so it needs a UFI too. Finished cosmetics are outside CLP altogether. The body oil is covered by the Cosmetics Regulation, the CPSR and CPNP. Only the diffuser needs a PCN.
• My UK company can file the PCN for my EU stockists. A non-EU company cannot be the duty holder. Your EU importer files, or you make a voluntary submission through an EU-based legal entity and give the importer your UFI to reference.
• One UFI covers my whole scent range. Only if the mixtures share the same composition, or qualify for a group submission where the products differ only in perfumes totalling 5% or less. Most diffusers and wax melts carry far more fragrance than that, so each scent usually needs its own UFI.
• If it is not classified for the environment it is out of scope. It is the other way round. Health and physical hazards trigger PCN. An aquatic-only classification does not.
• Brexit means I can ignore PCN for UK sales. For England, Scotland and Wales, yes, there is no mandatory notification. Northern Ireland still applies EU CLP and Annex VIII.

What to do this week

1. Pull up the CLP classification for each product from its SDS and check for any health or physical hazard class.
2. Rule out finished cosmetics and products classified only for aquatic hazard; list everything else that is sold in the EU or Northern Ireland.
3. Agree in writing who the EU duty holder is for each country before the first shipment.
4. Ask your fragrance oil supplier whether the oil already has a UFI and a PCN behind it.
5. Generate a UFI per mixture with ECHA's free tool and add "UFI:" plus the code to the label artwork.
6. Build the dossier in IUCLID Cloud or desktop, validate it, then submit through the ECHA submission portal for each country where you sell.
7. For Northern Ireland, export the dossier as an .i6z file and email it to sds.npis@nhs.net.
8. Keep the submission reports with the technical file and update the notification whenever the formula, classification or label changes.

Frequently asked questions

Official sources and legislation

• EU CLP Regulation (EC) No 1272/2008, Article 45 and Annex VIII (EUR-Lex)
• Commission Delegated Regulation (EU) 2020/1677 replacing Annex VIII (EUR-Lex)
• Regulation (EU) 2024/2865 amending CLP, including Article 45 and Annex VIII (EUR-Lex)
• GB CLP Article 1: scope and cosmetics exclusion (legislation.gov.uk)
• ECHA Poison Centres: prepare and submit a PCN
• ECHA Poison Centres: UFI generator
• ECHA Poison Centres: know your obligations
• GOV.UK: submitting chemicals information to the National Poisons Information Service
• HSE: National Poisons Information Service and mixtures placed on the GB market