GHS/CLP Pictogram Diamonds: can they be left blank or do they have to be blacked out?
Pre-Printed Label Stocks
When producing GHS/CLP supply labels, it’s common practice to use pre-printed labels stocks containing the blank, red diamonds. The background is overprinted with the specific label information and the relevant black pictogram symbols are printed inside the red borders.
For companies with a number of substances and preparations, this may mean that either multiple label formats are required, with the exact number of pre-printed diamonds, or that labels are printed with up to five red diamonds and the ones that aren’t required are left empty.
What Do The CLP Regulations Say About Blank Pictogram Diamonds?
The CLP regulations do not explicitly forbid blank diamonds.
However, Article 25(3) requires that: “any information which goes beyond the mandatory label elements, must not contradict or cast doubt on the messages provided by the latter”, and red diamonds that are left empty may certainly raise questions as to whether they should have something in them, or not.
Therefore, in order to comply with the regulations, red diamonds should NOT be left intentionally blank with an empty pictogram.
The ECHA Guidance on CLP Labelling and Packaging (version 4.2, 2021, pages 29/30) recommends that either:
- the correct number of pictograms are printed on the label, or
- the blank red diamonds are completely blacked-out, in order to avoid the impression that relevant hazard symbols may have been left off the label due to a printing mistake.
Label with pictograms blacked out.
Be advised, that if the blank red frame is not FULLY covered and filled in, the label would not be in compliance.
For confirmation, and further information, see section 4.3.4 of the ECHA Guidance Document on CLP Labelling and Packaging.
If you have further questions, or require assistance with CLP labelling, please feel free to contact us on 0113 2424 272