Registration of chemical products with PCN and UFI: Protect your business from fines in the EU

As of January 1, 2025, the registration requirements for hazardous mixtures have become mandatory. For companies placing products on the EU market or importing them into the European market, simply submitting a registration to the ECHA PCN is not enough – the correct generation and linking of the UFI code is crucial.

The KRP Consulting Group team comprehensively supports foreign manufacturers in achieving full compliance with the CLP (1272/2008) and REACH (1907/2006) regulations. We understand that simply slapping a UFI code on a label without activating the associated dossier in the system is a surefire path to severe sanctions.

The Role of KRP CG as Your Authorized Representative

Under EU law, a non-EU manufacturer cannot independently submit data to poison control centers without having legal personality within the EU. The KRP CG assumes the role of "Responsible Person," ensuring:

• Generation and legal activation of UFI codes: We ensure that the code is unique and correctly assigned to the chemical composition.

• Submitting dossiers via the ECHA portal (PCN Notification): We manage the notification process according to a harmonised format.

• Communication with regulatory authorities: We represent your interests before inspections and poison control centres in 27 EU countries.

  
  

  

Judicial and administrative practice in Poland

In Poland, the Office for Chemical Substances and the State Sanitary Inspectorate (Sanepid) oversee the trade in chemicals. Polish law (the Act on Chemical Substances and Their Mixtures) provides for stringent disciplinary measures:

• Administrative fines: For placing a mixture on the market without the required registration or with an incorrect UFI code, financial penalties of up to PLN 200,000 are imposed in Poland for each detected violation.

• Administrative Court Case Law (WSA): Polish court practice ( including judgments of the WSA in Warsaw) clearly confirms that the importer bears full responsibility for the correct classification and labeling of the product. In cases where the actual composition did not correspond to the data in the Safety Data Sheet (SDS), courts have upheld decisions to immediately withdraw the product from the market and imposed maximum penalties.

• Criminal aspect: According to the Penal Code, the deliberate introduction of hazardous substances into circulation without due notification to health authorities may result in criminal liability for the company's managers.

  
  

Safety checklist from KRP CG

As your representative, we conduct a thorough audit before shipping the first batch of goods:

1. SDS Verification: Is the format compliant with the current Regulation 2020/878?

2. Language adaptation: As required, the dossier and labels must be written in the official language of the destination country (e.g. Polish for the Polish market, German for the German market).

3. Labeling synchronization: The UFI code on the label must be identical to the code in the PCN database. Even the slightest error in the symbols will invalidate the registration during inspection.

Risk of ignoring registration obligations

For KRP CG clients, we define three main risk areas:

• Customs block: The National Revenue Administration (KAS) increasingly verifies the presence of an active UFI code already at the customs clearance stage.

• Financial losses: The costs of the product recall procedure from the shelves of European supermarkets often exceed the value of the batch of goods itself many times.

• Loss of reputation: Being included in the Safety Gate system (RAPEX) means being included on a public list of dangerous products, which practically closes the door to cooperation with large distribution networks in the EU.

KRP Consulting Group – your secure base in the European Union. We don't just register products – we minimize legal and financial risk, allowing you to focus on growing your sales.

Please contact us today to verify the readiness of your products for the tightened requirements for 2025-2026.