Chemical Labelling Regulations
A quick breakdown of what the new legislation is suggesting, what might change, and our thoughts.
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What amendments have been called for?
There have been suggested changes to the way your chemicals are labelled by the European Commision under CLP, but what does it actually mean?
At present (5th June 2023) there are no official label changes to be made for chemicals sold in Europe as Parliament has responded with a substantial list of amendments to the proposal.
Original Requests & Parliamentary Amends as follows:
1. Obligatory Formatting (inc. minimum font sizes)
– Text background to be white Parliament counter-proposed for removal.
– Minimum font sizes of 8pt, 12pt, 16pt and 20pt Parliament have counter-proposed, but would suggest the fonts be as per below:
Packaging not exceeding 3 litres: Minimum of 4pt
Greater than 3 litres, but not exceeding 50 litres: Minimum of 6pt.
Greater than 50 litres, but not exceeding 500 litres: Minimum of 8pt.
Greater than 500 litres: 10pt.
– Line spacing needed to be equal or above 120% of the font size used. Parliament counter-proposed for removal.
– Letter spacing needed to be appropriate and legible. Parliament counter-proposed for removal.
2. Digital Labels
– Some information would be made available on a ‘digital’ or cloud-based label, and can only be used in conjunction with the necessary hazard measures currently in place.
Parliament appears to have accepted for EU Fertilising Products.
3. Products Sold Online
– The same CLP labelling rules should apply to products sold online within the EU.
Parliament counter-proposed the below:
The hazardous product advertisement should include: “Any advertisement for the sale to the general public of a substance classified as hazardous, shall request the user to always read and follow product label information” relevant hazard pictogram, signal word, hazard class and hazard statements.
4. Booklet Labels
– No firm proposal, but more solid references to this type of label throughout the document. May be considered for future proposed changes.
5. Label Update Timeframe
Referring to hazard classifications of products and changes to these classifications:
– a new hazard class or severe classification should be updated no later than 6 months after the new evaluation.
– a less severe hazard or new supplemental labelling requirement should be updated no later than 18 months.
Parliament counter-proposed that both of these should be updated within an 18-month period.
Current EU CLP Guidance by the EC is here.
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