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esdscom / sdscom-xml

Schema definition and other documents of eSDScom (formerly SDScom and ESCom), the standard for electronic exchange of Safety Data Sheets in a structured, processible way across Europe and other regions. Please read the wiki for more info. All work is licensed under CC BY-ND 4.0 (https://creativecommons.org/licenses/by-nd/4.0/legalcode)
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Position of UFI in the SDS #200

Closed dirk-qualisys closed 5 years ago

dirk-qualisys commented 5 years ago

This is a follow-up to issue #187, UFI support. Current implementation foresees UFIs to be printed in section 1 of the SDS, but this might need to be changed to 2.2. I received the following info from an interested software company. Any other sources of info?

Reach Annex II (Commission Regulation (EC) 2015/830):

“2.2. Label elements Based on the classification, at least the following elements appearing on the label in accordance with Regulation (EC) No 1272/2008 shall be provided: hazard pictogram(s), signal word(s), hazard statement(s) and precautionary statement(s). A graphical reproduction of the full hazard pictogram in black and white or a graphical reproduction of the symbol only may be substituted for the colour pictogram provided in Regulation (EC) No 1272/2008. The applicable label elements in accordance with Article 25 and Article 32(6) of Regulation (EC) No 1272/2008 shall be provided.”

Article 25 in CLP was updated in the amendment Commission Regulation (EU) 2017/542 to include UFI: “In Article 25, the following paragraph 7 is added: ‘7. Where under Annex VIII the submitter creates a unique formula identifier, it shall be included on the label in accordance with the provisions of Section 5 of Part A of that Annex’”

Also, in this presentation from ECHA, slide 14 it is stated that the UFI is a label element and should be included in section 2.2: https://echa.europa.eu/documents/10162/23912754/260418_ufi_webinar_what_is_a_ufi_en.pdf/1d040135-fe4a-6f5c-cea9-3376aa02d973

When it comes to the requirement to include it in section 15 for industrial products this is stated in the presentation above – slide 15 and in an FAQ on the poison centers website: https://poisoncentres.echa.europa.eu/sv/questions-and-answers

dirk-qualisys commented 5 years ago

There is a draft of a new Annex II under way which clarifies that the UFI should go in section 1. The current situation derives from the UFI being defined later than Annex II. So we can wait.