Annex VIII of CLP, introduced by Regulation (EU) 2017/542, phased in by intended use. All phases are now closed, including the transitional period for mixtures that had only ever been notified under a national scheme.
| Deadline | Scope | Practical consequence now |
|---|
| 1 January 2021 | Consumer-use hazardous mixtures. | Any consumer mixture on the EU market without a harmonised PCN and a UFI on the label is non-compliant today. |
|---|
| 1 January 2021 | Professional-use hazardous mixtures. | Same duty. Professional-only packs are the ones most often missed in legacy ranges. |
|---|
| 1 January 2024 | Industrial-use hazardous mixtures. | Industrial mixtures can use the limited submission route, but still need the UFI and a notification. |
|---|
| 1 January 2025 | End of the transitional period for mixtures already notified under national systems before their phase-in date. | Legacy national notifications no longer cover you. Anything not migrated to a harmonised PCN needs it now. |
|---|
Three failure modes account for most enforcement findings: a UFI on the label that no longer matches the notified composition after a raw material swap, a mixture-in-mixture where the supplier's composition is unknown and the notification is filed on assumptions, and a UFI reused across SKUs whose compositions have quietly diverged. Each is a data-lineage problem, which is why the UFI is best generated from the substance master inside chemical compliance software and printed through the same system that produces CLP labelling and the safety data sheet.