In case you missed it..
Back in September, the EC made further proposed changes to labels under the new amendment to CLP (Classification, Labelling and Packaging of Chemicals legislation). You can view the Report here.
It is important to note that these proposed changes are still unofficial and no timescale has been given for the implementation of the amendments.
The issue of the increased font sizes for labels in still causing much concern; thanks to Janet Greenwood of TT Environmental for her diligence in this issue and spotting the crucial bit of information that the text size of labels is to be measured from the x-height (height of a lower-case x) rather than the whole height of the font, including ascenders and descenders.
This revelation means that fitting the necessary information onto standard-sized labels will still remain an impossible task for most substances and mixtures. See Janet’s latest update on this issue.
Font Sizes
The font sizes of labels has now been shown in millimetres rather than point size, in order for the text to actually be measured more easily. However, regardless of the choice of font, the measurements would be taken from the x-height of the characters. The x-height differs from font to font and can have a large impact on the readability of text.
As previously mentioned, the other format changes to labels, including a mandatory white background, and line spacing have been removed from the proposal.
Other Label Amendments
Amendments to the proposal include further hazard classifications falling under Child-Resistant Fastenings, and Tactile Warnings of Danger requirements. It is proposed that tactile warnings will now be required for relatively low level hazards such as skin and eye irritants supplied to the general public:
“3.2.1. Packaging to be fitted with a tactile warning
Where substances or mixtures are supplied to the general public and classified for acute toxicity, skin corrosion/skin irritation, serious eye damage/eye irritation, endocrine disruption for human health category 2, endocrine disruption for the environment category 2, germ cell mutagenicity category 2, carcinogenicity category 2, reproductive toxicity category 2, respiratory or skin sensitization, STOT categories 1 or 2, aspiration hazard, flammable gases, flammable liquids categories 1 or 2, or flammable solids, the packaging of whatever capacity, shall be fitted with a tactile warning of danger. “
Another amendment was the specification for multi-language labels to have the languages ordered in a logical way, eg, alphabetically.
Industry groups revolt against new labelling requirements
Since our last update, several industry groups have come together to request modifications regarding the new labelling requirements, due to their major impact on the industry.
These groups believe that the Commission’s impact assessment underestimates the impact of the changes proposed in the CLP revision, particularly with regard to labelling requirements.
According to these groups, several points are problematic:
- The amendment submitted in the European Parliament to ban environmental claims on mixtures classified as hazardous or carrying additional labelling. According to them, the scope of CLP should “remain solely focused on the hazard identification of chemicals and the associated classification, labeling and packaging” and that the prohibition on environmental claims in mixtures goes beyond the scope of CLP and conflicts with other proposals made within the EU.
- The proposal to increase the minimum font size on labels. The new sizes could lead to an increase in the space required to display information on packaging, and a reduction in the number of languages on packaging. This could potentially hamper the fluidity of trade within the European Union, and lead to the probable elimination of products reaching their expiry date.
- The 6-month timetable for label updates. A 6-month timeline for label updates is unworkable in their view. When changing classification and labelling, the artwork re-design process alone takes a single supplier in the CLP supply chain approximately 9 – 12 months, in addition to identifying, generating and evaluating new data and any research and development required to re-formulate products.
Background – Revision of the CLP Regulation
In December 2022, the European Commission (EC) proposed a revision of European Regulation No. 1272/2008, for the classification, labelling and packaging of substances and mixtures (CLP). The Commission also suggested changes to the minimum requirements for the labelling of hazardous chemicals.
The amended regulations provide for :
- Specific guidelines for refillable chemicals, enabling consumers to safely purchase and use bulk chemicals such as cleaning products, while ensuring their safety.
- Improved communication of chemical hazards, including online, through simpler and better-defined labelling and advertising rules.
- A wider use of fold-out/booklet labels and digital labels.
For more information please consult our previous posts.
What Next
The legislative Act has been returned to the committee and everyone is waiting to see what their response will be as any changes can now be made without requiring additional debate. This encompasses the potential acceptance or rejection of any previously assumed changes.
The ultimate outcome remains uncertain until the final version is officially released. The timeline for publication is unknown. Similarly, the implementation timescales will only be clear once the publication is made, so stay tuned for updates.
Do NOT make any amendments to your labels on the basis of these proposals – it is possible that further alterations may be implemented before the actual publication of any legal text.