CLP 2027 – distributor's UFI, PCN & poison information for relabeling | Word/PDF/Excel

Do you sell cleaning products, paint, glue, or other hazardous chemical mixtures under your own brand – or are you starting to supply an existing mixture to another EU/EEA country? From 1 January 2027, a distributor may need to ensure that the relevant poison centres have the correct information in accordance with Article 45 and Annex VIII of CLP. This Swedish specialist package helps you document the UFI, trade name, target market, the supplier’s PCN coverage, and any own notification requirements.

Difference from a general chemical policy: the template is based on an actual retail flow, not a general risk assessment. If the supplier has already provided all the necessary information for your mixture, market, and the relevant product identifiers to the relevant authorities, a separate distributor notification may not be required. However, a UFI code alone is not proof that a PCN has been sent to the correct country or covers the new product name.

Five Swedish working templates – a specific distributor flow

1. A01 – Role assessment: determines whether you are acting as a distributor, whether the product is a mixture, and whether it is classified as hazardous to health or physically hazardous. Distinguish substances, only environmentally hazardous mixtures, and existing importer/manufacturer requirements.
2. A02 – Supplier letter: request confirmation and traceable evidence of which countries, UFI codes, trade names, and formulations are covered by the supplier’s poison centre notification.
3. A03 – Country, name, and UFI: perform a separate check of the actual destination market, language, new label, product identifiers, and reference to the correct PCN documentation.
4. A04 – Choice of PCN route: document whether the supplier should supplement its notification or whether the distributor needs to prepare its own PCN via ECHA’s official portal. If necessary, check a MiM solution for confidential mixtures.
5. A05 – Label and release: record affected batches, deviations, corrective actions, and a signed internal decision. An administrative Excel status may never be considered proof of official receipt.

Excel register with nine tabs

Overview, Mixtures, Markets, Supplier Evidence, PCN Plan, UFI Label, Changes, Decisions, and Sources. The workbook contains 707 formulas to compile entered products and identify, among other things, PCN CHECK REQUIRED, SUPPLEMENT COVERAGE, REQUEST SUPPLEMENTATION, and UNVERIFIED. New rows can be filled in within the prepared registers. A pre-set formula cannot prove correct chemical classification, submission, or legal validity.

Which rule applies from 1 January 2027?

Regulation (EU) 2024/2865 amends Article 45 and Annex VIII of the CLP Regulation. From 1 January 2027, the obligations of certain distributors who sell hazardous mixtures to another EU/EEA country, change product names, or relabel products are clarified and expanded. A separate notification is not required if the distributor can show that all necessary information has already been provided to the relevant authorities via the supplier. See the Swedish Chemicals Agency’s guidance.

Not all chemicals are covered. The harmonised PCN information under Article 45 applies to mixtures classified as hazardous to health or physically hazardous. Pure substances and mixtures classified only as environmentally hazardous are not covered by this specific requirement; other CLP labelling and national obligations may still apply. Manufacturers, downstream users, and importers of certain mixtures already have existing obligations.

Do not confuse the dates: the rules for certain new CLP label formats, relabelling deadlines, advertising, and distance selling have been postponed to 1 January 2028 by (EU) 2025/2439. This postponement does not change the distributors’ specific PCN start date under Article 45 in January 2027.

Real-world use cases

Private label: a Swedish cleaning company sells a hazardous-to-health cleaning mixture under a new brand. The template helps document whether the new trade name is included in the notification. Cross-border B2B: a Swedish distributor starts selling the same mixture in Finland; Finnish market coverage must be checked separately. Product already covered: the supplier can confirm the country, product name, and notification status; the distributor archives the evidence and determines that a new PCN is not required.

Frequently asked questions

Must all retailers submit their own PCN in 2027?

No. The specific distributor obligation applies, among other things, in the case of cross-border sales or the renaming/relabelling of certain hazardous mixtures, and a separate submission may be avoided if it can be shown that the relevant authorities already have the necessary information.

Is it enough for the supplier to send us a UFI code?

No. A UFI identifies the composition of a mixture but does not prove that the relevant destination market and all relevant trade names are covered by a valid notification. Request evidence of the country and product identifiers.

Must a product classified only as environmentally hazardous be notified under Article 45?

No, not under the harmonised PCN obligation based on health or physical hazards. However, check other applicable chemical regulations and whether the classification is indeed correct.

Can I send the Excel file to ECHA as a completed PCN?

No. Excel is an internal register. An official PCN requires relevant chemical information, the correct IUCLID/ECHA format, an authorised submitter, and actual submission via ECHA’s system.

Can the supplier keep its trade secret?

Yes, the workflow can begin with the supplier updating the existing notification itself. ECHA also describes specific MiM arrangements that can be applied under the regulations when submitting your own notification. The choice requires technical review.

Are all working templates in English, and are the PDF files fillable?

Five working templates and the Excel file are in Swedish. One Swedish and one separate English user guide are included. DOCX is editable, and PDF is searchable/printable but is not an interactive form.

Sources, limitations, and delivery

EU sources: CLP (EC) 1272/2008, Article 45 and Annex VIII; (EU) 2024/2865; (EU) 2025/2439. Official guidance: Swedish Chemicals Agency – The company’s role and ECHA – Supply chain and PCN.

Version 1.0. Internal AI-assisted legal source check 9 November 2026. No external independent legal review, chemical expert certification, real UFI generation, ECHA PCN submission, or official verification has been performed. The template is a documentation aid, not a guarantee of legal sale. The digital ZIP file will only be manually linked to the download app after a specific decision to publish the product.