The guide · CLP Annex VIII
The European Product Categorisation System (EuPCS)
Every notified mixture needs a product category as well as a composition. The European Product Categorisation System describes what the mixture is used for — not what it contains — and a poison centre often reaches for that before it reaches for anything else on the file.
What EuPCS is for
When someone calls a poison centre about a household cleaner, an adhesive or a dishwashing detergent, the operator rarely starts by asking for a UFI — they start with what the product is, because that already narrows down the likely exposure and the likely response before any composition data comes into play. The EuPCS category is what carries that information into the dossier: a harmonised, EU-wide way of describing intended use, maintained by ECHA, so that the same category means the same thing whichever member state's poison centre is reading it. It also feeds statistics on which types of product generate the most calls, which is part of why the categories keep being refined.
Before EuPCS existed, this description had no fixed vocabulary at all — a formulator would write whatever free text seemed reasonable, and a poison centre in one member state had no guarantee it meant the same thing as similar free text filed with a different appointed body. A single shared category list is what makes it possible to compare notification data across the whole EU, not just to read one dossier at a time.
How to choose a category
EuPCS is organised as a decision tree rather than a flat list. You start from a broad branch and move through progressively specific sub-categories, and the code you actually declare reflects that path — a scented candle, for instance, moves from a general product branch down through an air-care category to a specific candle sub-category, and it is that most specific, terminal entry that gets used, not the broader category sitting above it. A category that still has sub-categories beneath it is usually a staging point on the way to the right answer, not the answer itself.
The categories most often chosen wrongly
Most of the mistakes we see are not about the composition at all — they are about matching a marketing description to the tree instead of matching the actual intended use. A product sold as a "surface care" item under a brand's own naming convention still needs to be walked down to whatever the tree calls that specific function; the shelf category and the EuPCS category are not the same vocabulary. The other recurring pattern is stopping one level too early — picking a plausible parent category because it is close enough, rather than continuing down to the specific child that actually exists for that product and carries the more precise information a poison centre would want.
Multi-purpose products
Some mixtures genuinely are sold for more than one use — a concentrated detergent that reaches both household and professional cleaners, for example. EuPCS does not require a separate category for every channel that product happens to reach; the notifier assigns the category that matches the use they are actually declaring the mixture for, and nothing about that categorisation stops the same product being sold to other types of user under it. Where the difference between channels is not just who buys it but an actual change to the formulation or the pack, that stops being a categorisation question and becomes a composition one — how that distinction is drawn is explained on our new-UFI decision page.
Where the category appears in the dossier
The EuPCS category sits in the product information section of the submission, alongside the mixture's packaging, colour, physical state and pH. See the full section-by-section breakdown of the dossier for how this fits with everything else being declared around it.
It is worth getting right before the rest of that section is filled in rather than after, since the category is one of the few fields that shapes how a poison centre reads everything else on the file — the same composition can be interpreted quite differently depending on whether the operator understands the product in front of them as an industrial degreaser or a household surface cleaner.
Next step
Not sure which category your product belongs in?
We work through the EuPCS tree with you, assign the category the dossier actually needs, and build the rest of the submission around it.