CLP: EC PROPOSES MAJOR OVERHAUL OF CHEMICAL LABELLING INCLUDING MINIMUM FONT SIZES
EC UNVEILS PROPOSAL TO REVISE EU CHEMICAL LABELLING RULES
On 19th December 2022, the European Commission proposed a revised Regulation on the classification, labelling and packaging of chemicals (CLP) and introduced five new hazard classes for endocrine disruptors and other harmful substances. The addition of these new hazard classes means that relevant chemical manufacturers will need to update the labels on their packaging, Safety Data Sheets, and REACH registration dossiers.
However, it is the proposed changes to label formatting that could have far wider implications for the rest of the chemical industry. These proposed amendments, aimed at improving the communication of chemical hazards, include significant changes such as minimal font sizes and changes to the layout of labels.
NEW LABELLING PROPOSALS
In order to improve the hazard communication of chemicals the EC suggested 5 measures:
- Obligatory formatting rules for labels
- A framework of rules for selling chemicals in refillable containers
- Voluntary partial digital labelling
- A broader use of fold-out labels
- Additional derogations for chemicals sold to consumers in bulk (such as fuel) and in very small packaging (such as writing instruments)
OBLIGATORY FORMATTING RULES FOR LABELS
The new formatting rules aim to increase the visibility and legibility of important information on chemical labels. One key aspect of this proposal is the introduction of minimum font sizes for labelling text.
It is also proposed that the text on the label shall have the following characteristics:
(a) the background of the label shall be white;(b) the distance between two lines shall be equal, or above, 120 % of the font size; (c) a single font shall be used that is easily legible and without serifs; (d) the letter spacing shall be appropriate for the selected font to be comfortably legible.
The following table from the proposal indicates the minimum dimensions of the label, the pictogram, and the font size of letters:
|Capacity of the package:||Dimensions of the label (in millimetres) for the Information required by Article 17||Dimension of each pictogram (in millimetres)||Minimum font-size|
|Not exceeding 3 litres:||If possible, at least 52x74||Not smaller than 10x10|
If possible, at least 16x16
|Greater than 3 litres but not exceeding 50 litres:||At least 74x105||At least 23x23||12pt|
|Greater than 50 litres but not exceeding 300 litres:||At least 105x148||At least 32x32||16pt|
|Greater than 500 litres||At least 148x210||At least 46x46||20pt|
The following label example shows the text at the proposed size for a 5L container (74x105mm). The necessary elements, with the text at 12pt, take up the full size of the label with no room left for contact details or other information. If a substance, or mixture, requires more than 2 hazard pictograms, or a larger amount of phrases, this would be impossible to configure and a larger label would be required – having a knock-on effect on the amount of material needed for the label, and also the cost and subsequent waste thereafter. This could also lead to companies aiming to minimise the number of phrases per label, resulting in the end user having less information at hand.
SELLING CHEMICALS IN REFILLABLE CONTAINERS
A framework of specific rules has been proposed that will ensure that hazardous chemicals sold in refillable containers does not lead to any increased risks. This method of sale will be limited to chemicals with less severe hazards.
VOLUNTARY PARTLY DIGITISED LABELLING
BROADER USE OF FOLD-OUT LABELS
LABELLING OF ONLINE SALES
Online marketplaces are not defined as ‘importers’ nor ‘economic operators’ and therefore EU Member State authorities cannot enforce EU chemicals safety laws for goods sold online, especially if online marketplaces are registered outside of the EU.
It is proposed that the same classification, labelling and packaging obligations should apply to online sales and that chemicals sold online, in the EU market, must be in compliance with the CLP regulations.
In addition, there will be an obligation on the advertising of hazardous substances and mixtures to contain all of the information which is most important in terms of safety and protection of the environment, and for the advertisement to contain the hazard pictogram, signal word, the hazard class, and the hazard statements.