16 Dec
In today’s blog we will be covering practical 2026 chemical compliance checklist for PCN, UFI, and REACH obligations in the EU. Learn how to prepare, avoid enforcement risks, and manage compliance efficiently with Chemius.
Why 2026 Is a Turning Point for Chemical Compliance
By 2026, European chemical compliance enters a stricter phase. Transitional periods under CLP and REACH are over, enforcement is harmonized across member states, and inspectors expect full alignment between formulations, Safety Data Sheets, Poison Centre Notifications, and labels.
For manufacturers, importers, and downstream users, this means one thing: tolerance for gaps is gone. This second part of the checklist focuses on Poison Centre Notification (PCN), Unique Formula Identifiers (UFI), and REACH substance management, with a practical lens on how to stay inspection-ready.
Poison Centre Notification (PCN) & UFI Compliance
Identify Notification Obligations
Start by mapping all mixtures placed on the EU market. Under CLP Article 45 and Annex VIII, any hazardous mixture classified for physical or health hazards must be notified to poison centres via ECHA’s submission portal.
Key points to verify in 2026:
- Consumer and professional mixtures should already be notified since 2021
- Industrial-use mixtures required notification by 1 January 2024
- Any new mixture, reformulation, or significant concentration change triggers a new PCN
With all grace periods finished, enforcement authorities will treat missing or outdated PCNs as non-compliance rather than legacy issues.
Generate and Control UFI Codes
Each unique mixture composition requires its own Unique Formula Identifier (UFI). This 16-character code connects the product label, SDS, and PCN dossier.
Best practices:
- One UFI per formulation, not per brand name
- Use new UFI for each brand, if disclosing the connection with the same UFI is not an option
- Keep a clear internal mapping between formulation versions and UFIs
- Update the UFI when composition changes exceed allowed tolerances
Within Chemius, UFI creation is integrated directly into SDS authoring. When a mixture composition is entered, the platform generates the UFI automatically based on Formula ID and VAT number of the company, ensuring alignment across documentation and reducing human error. More details are available at support@chemius.net
Compile the PCN Dossier
A compliant PCN dossier must follow ECHA’s harmonized format and include:
- Product identifiers (trade name, UFI)
- Full formulation with concentrations
- Hazard classification and toxicological data
- Use type (consumer, professional, industrial)
- Packaging details and emergency contact information
Creating this manually is time-consuming and prone to inconsistencies. Chemius reuses SDS data to guide users through PCN dossier creation step by step, applying built-in validation before submission to reduce rejection risk.
Submit and Maintain Notifications
PCN dossiers must cover all EU/EEA countries where the product is placed on the market. Through the ECHA portal, multi-country submissions are possible, but responsibility remains with the notifier.
Ongoing obligations include:
- Updating PCNs after formulation or packaging changes
- Assigning new UFIs when required
- Keeping submission confirmations accessible for inspections
Chemius allows direct submission to ECHA, status tracking, and grouped notifications for multiple products or brands. Once SDS data is complete, a compliant PCN can be prepared and submitted in minutes instead of days.
Read more: What is voluntary PCN?
Emergency Contact and Internal Readiness
Section 1.4 of the SDS must include a 24/7 emergency telephone number, accessible in the local language. Inspectors increasingly verify not just the presence of the number, but whether it works.
Internally:
- Ensure rapid access to full composition data
- Prepare procedures for responding to poison centre requests within one hour for limited submissions
- Periodically align formulations, SDSs, and PCNs
Chemius’ regulatory dashboard helps by showing which products have valid PCNs linked to their SDSs, reducing blind spots.
REACH Registration & Restricted Substances
Verify REACH Registration Status
By 2026, all standard REACH registration deadlines are long behind us. Any company manufacturing or importing substances at or above 1 tonne per year must ensure registration is complete and current.
Actions to take:
- Audit all substances in mixtures and articles
- Confirm supplier registrations or Only Representative coverage
- Watch for tonnage increases that require dossier updates
Upcoming regulatory changes may introduce time-limited registrations and expanded hazard classes. While Chemius is not a registration portal, it reflects updated classifications in SDSs and flags substances that gain new regulatory status.
For strategic REACH support and advisory services, companies often work with regulatory specialists such as https://www.bens-consulting.com, especially when dealing with complex supply chains or Only Representative arrangements.
Manage SVHCs and High-Risk Substances
The Candidate List of Substances of Very High Concern (SVHCs) continues to expand. In 2026, pressure around PFAS, endocrine disruptors, and CMR substances is expected to increase.
Compliance steps:
- Identify SVHCs above 0.1% w/w in mixtures or articles
- Fulfil REACH Article 33 communication duties
- Submit SCIP notifications for articles when required
- Track substances added to REACH Annex XIV and plan substitutions early
Chemius supports this by flagging substances in formulations that gain SVHC status or new harmonized classifications, allowing proactive updates before enforcement actions occur.
Comply with Annex XVII Restrictions
REACH Annex XVII defines concentration limits and use bans. New and upcoming restrictions to monitor include:
- Microplastics restrictions for mixtures and articles
- Expanded PFAS limitations across multiple applications
- Existing limits for phthalates, heavy metals, and solvents
During formulation or raw material changes, cross-check ingredients against restriction lists. Chemius’ ingredient database includes synonyms, helping identify substances that may appear under alternative names in regulatory texts.
Maintain Evidence and Inspection Readiness
Inspectors in 2026 will expect structured documentation:
- REACH registration numbers listed in SDS Section 1
- Authorization numbers in Section 15 when applicable
- Records of SVHC communication and SCIP submissions
- Supplier compliance confirmations
Using Chemius as a central repository ensures SDSs, PCN confirmations, and regulatory notes are accessible to regulatory, R&D, sales, and supply chain teams alike. This shared visibility reduces internal friction and inspection risk.
Closing Perspective
Chemical compliance in 2026 is no longer about meeting deadlines; it is about maintaining consistency across data, documents, and processes. PCN, UFI, and REACH obligations intersect, and misalignment between them is one of the most common causes of enforcement findings.
Platforms like Chemius provide structure and continuity, while expert advisory support from partners such as BENS helps companies interpret regulatory shifts and manage exceptions. Together, they allow organizations to treat compliance as a stable operational process rather than a recurring emergency.
Next week we will make part 3 of these chemical compliance tips and tricks. If you are in search of new SDS Authoring Software write us anytime at support@chemius.net.
