Guide to labelling of chemical products, including small packages

The GB CLP Regulation gives the criteria for classifying chemical substances according to their hazards, and for assigning pictograms, signal words, and hazard and precautionary statements for use on the label to communicate these hazards down the supply chain.

In this article Dr Mel Cooke of Alchemy Compliance addresses the legal requirements for labelling of hazardous chemicals, including reduced labelling for small packages, and labelling of detergents and aerosols, which use CLP labelling but require additional text.

The CLP Regulation has some concessions for smaller packages, acknowledging that the risk of harm to humans and the environment is reduced for smaller amounts of chemical.

Check out our handy glossary of definitions and abbreviations of technical terms used in this article.

More information on the services that we provide for hazard classification, SDSs authoring, or labelling is given here, or contact us.

Label elements

The GB CLP Regulation [1] gives the parts (‘label elements’) required on the label. These label elements are a combination of general information, such as the supplier and product name, and specialised symbols and text to quickly identify the hazards posed by the product. The names of label elements are given in Figure 1, and the descriptions below.

Label elements described in the classification, labelling and packaging regulation.
Figure 1: Label elements as specified in the CLP Regulation

Product identifier

For substances, the product identifier is typically the name in IUPAC nomenclature and the EC number or CAS registry number.

For mixtures, the product identifier comprises the trade name of the mixture, and the names of the component substances that contribute to the hazard of the mixture in the more severe health hazard categories [acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, respiratory or skin sensitisation, specific target organ toxicity (STOT) or aspiration hazard].

A maximum of four ingredient names is recommended (CLP Regulation, Article 18).

Pictograms

Pictograms are assigned according to Annex I of the CLP Regulation, depending on the hazard classification.
For example flammable liquids have the pictogram:

CLP flame pictogram

The pictogram design is specified in Annex V of the CLP Regulation, and comprises a symbol inside a red ‘square set on point’ border.

There are rules of precedence given in CLP Article 26, that help reduce the number of required pictograms. Nevertheless, up to five pictograms may be necessary on the label, depending on the hazard classification of the substance or mixture.

Table 1 gives the minimum dimensions of the pictogram, which is dependent on the package size.
The pictogram must be at least 1/15th the size of the minimum label dedicated to the obligatory labelling information. For packages of < 3 L capacity, the recommended pictogram size is 16 × 16 mm, and the minimum pictogram size is 10 × 10 mm.

Signal Words

Most hazard categories have a signal word, ‘danger’ or ‘warning’ associated with them. A few, such as ‘Aquatic Hazard (Long-Term), Category 3’ do not carry a signal word. Only one signal word is allowed on the label, with precedence being given to the more severe ‘danger’ if both apply (CLP Regulation, Article 20).

Hazard Statements

Each hazard category has an associated hazard statement (see CLP Regulation, Annexes I and III). For example, ‘Eye Irritation, Category 2’ requires the hazard statement H319: ‘causes serious eye irritation.’ All hazard statements should be included on the label, unless there is obvious duplication or redundancy (CLP Regulation, Article 27).

Only the actual text of the hazard statements is required on the label. The code number, eg H319, given in the CLP Regulation may be helpful for identifying the hazard statements for translation purposes.

Precautionary Statements

Each hazard category has several associated precautionary statements, indicated in the CLP Regulation, Annex I, which give instruction on how to handle the product safely (see CLP Regulation, Annexes I and IV). They are divided into 5 types:

  • General
  • Prevention
  • Response
  • Storage
  • Disposal

For example, the CLP Regulation suggests the following precautionary statements for a highly flammable liquid (classification: Flam Liq 2, H225: highly flammable liquid and vapour), such as alcohol:

  • General: These are assigned to consumer products, eg P102: Keep out of reach of children.
  • Prevention: P233: Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking. Keep container tightly closed. P240: Ground/bond container and receiving equipment. P241: Use explosion-proof electrical/ventilating/lighting/…/ equipment. P242: Use only non-sparking tools. P243: Take precautionary measures against static discharge. P280: Wear protective gloves/protective clothing/eye protection/face protection.
  • Response: P303 + P361 + P353: IF ON SKIN (or hair): remove/take off immediately all contaminated clothing. Rinse skin with water/shower. P370 + P378: In case of fire: Use … for extinction.
  • P403 + P235: Storage: Store in a well-ventilated place. Keep cool.
  • Disposal: P501: Dispose of contents/container to … [… in accordance with local/regional/national/international regulation.

A product with a complicated classification may have many potential precautionary statements. ECHA Guidance [2] gives advice on choosing the most appropriate, so that a recommended maximum of six appear on the label (CLP Regulation, Article 28). The precautionary phrases can also be grouped together into longer statements as a way of reducing their number.

As for the hazard statements, the codes are not mandatory in the SDS or on the label.

Supplemental information

Supplemental information, in addition to the above label elements, may be required. Supplemental information may originate in the CLP Regulation, or other regulations, and may relate to certain hazards or special types of product, for example:

  • Some hazards that are not included in the UN GHS [3] but which require identification in the UK and EU, are given ‘EUH’ phrases in the CLP Regulation, eg EUH066 ‘Repeated exposure may cause skin dryness or cracking.
  • Mixtures containing certain substances require special labelling advice, eg EUH204 ‘Contains isocyanates. May produce an allergic reaction.’
  • Mixtures that contain substances with no data on their acute toxicity to mammals, require a phrase, ‘x% of the mixture consists of component(s) of unknown acute toxicity.’
  • Mixtures with no toxicity data for aquatic organisms, require a phrase, ‘contains x% of components with unknown hazards to the aquatic environment.’
  • Additional labelling information may be required by regulations for specialist products such as detergents or aerosols (see below)
  • Additional labelling information may be required by the REACH Regulation such as those subject to authorisation or restriction on marketing and use, eg products classified for carcinogenic effects. require the phrase ‘restricted to professional users’.
  • Unique formula identifiers (UFIs), the code used for poison centre notifications (described in the CLP Regulation [4], Annex VIII), are required on the label for EU and Northern Ireland, but not GB.

Supplier information

The supplier’s name, EU address and telephone number are required on the label.

Nominal quantities

The nominal quantity should also be placed on the label, or elsewhere on the packaging, if the product is sold to the general public.

Detergents

Detergent means any substance or mixture containing soaps and/or other surfactants intended for washing and cleaning processes, so covers a broad range of household and industrial cleaning products.
In addition to the labelling from the CLP regulation, based on the hazard classification, the Detergents Regulation (648/2008 [5]) requires the following label elements:

  • Specific types of ingredients: perfumes, optical brighteners, preservatives, and certain fragrance allergens (present at > 0.01 wt%)
  • Specific ingredients (present at >0.2 wt%): phosphates, phosphonates, surfactants (anionic, ionic, non-ionic and amphoteric), oxygen- or chlorine-based bleaching agents, EDTA and salts, nitrilotriacetic acid and salts, phenols, paradichlorobenzene, aromatic hydrocarbons, aliphatic hydrocarbons, halogenated hydrocarbons, soap, zeolites, polycarboxylates. Their concentration is also given on the label within prescribed percentage ranges (eg 5% or over but less than 15%)
  • the address, email address, and telephone number for the confidential ingredient listing for medical personnel.
  • the website address for a simplified, non-confidential version of the ingredient data sheet for consumers.
  • If the detergent is not meant for consumers, then the following phrase should appear on the label: ‘For professional use only’.

There are additional labelling requirements specifically for consumer laundry products (particularly instructions for use and dosing), and automatic dishwasher detergents.

Aerosols

Aerosols are a hazard class within the CLP Regulation. They also have their own legislation – the Aerosol Dispensers Directive (ADD) [6] – that contains additional requirements for labelling.

Their hazard classification is based on its components, its heat of combustion and the results of the foam test (for foam aerosols) or the ignition distance test (for spray aerosols).

The CLP label elements must be present: pictogram, signal word, and hazard and precautionary statements.

Recommended precautionary statements are given. For example, for Aerosol, Category 2, H223: Flammable Aerosol; H229: Pressurised container: May burst if heated:

  • P210: Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking.
  • P211: Do not spray on an open flame or other ignition source.
  • P251: Pressurized container: Do not pierce or burn, even after use.
  • P410 + P412: Protect from sunlight. Do not expose to temperatures exceeding 50 °C/122 °F.

The ADD stipulates further label elements. Some of the warning text is the same or similar to that of the CLP Regulation, and warnings need not be given twice. Label text particular to the ADD are:

  • ‘Inverted epsilon’ mark to certify conformity with the ADD.
  • Code to identify filling batch.
  • The net contents by weight and by volume, although there is a derogation in Directive 2007/45/EC that the nominal weight of the contents need not be given for aerosols. This Directive also requires the nominal total capacity (brimful capacity) to be marked.
  • Where an aerosol dispenser contains flammable components, but is not considered as ‘flammable’ or ‘extremely flammable’, the quantity of flammable material must be stated, ie ‘X % by mass of the contents are flammable’.

Some aerosol products do not require classification, and therefore labelling, for Aspiration toxicity.

Small package labelling of aerosols apply at <150 mL, cf 125 mL for non-aerosol products.

Language and translation of labels

Labels have to be in English for the UK. If imported from outside the UK, it is the responsibility of the UK-importer to make sure the label is in English.

For export to the EU and further afield, the label should be in the appropriate local language. The UK exporter has no legal obligation to translate the SDS or label. However, they will often do it to ease sales, as the customer may expect the translation to be done for them.

Some suppliers will therefore often look to include multiple languages on their labels. The volume of information means that labelling can be a particular problem of space and legibility.

The CLP labelling information for a particular language should be grouped together (CLP Article 32.3).

Size of the hazard label

The CLP Regulation gives the minimum dimensions for chemical labelling as given in Table 1 below.

Capacity of the package (L)Dimensions of the label (mm)Dimensions of the pictogram (mm)
Not exceeding 3If possible at least 52 × 74Not smaller than 10 × 10; if possible at least 16 × 16
> 3 but ≤ 50At least 74 × 105At least 23 × 23
> 50 but ≤ 500At least 105 × 148At least 32 × 32
> 500At least 148 × 210At least 46 × 46
Table 1: Minimum dimensions of the label, depending on the size of the package

For the smallest capacity package of less than 3 L, there is some wiggle room given in the interpretation of the minimum label dimensions, because of the phrase ‘if possible’ in Table 1.

The recommendation is to have the minimum label dimensions of 52 and 74 mm (total label area of 3848 mm2). However, where this is not feasible, then taking into account that the pictogram should be at least 1/15th of the label area, and using the figure of a minimum pictogram dimension of 10 × 10 mm, the minimum label area would be 1500 mm2.

Font size and legibility

There is no minimum font size specified in the CLP Regulation, but Article 31 states that the text should be of such size, spacing and contrast as to be easily read.

The ECHA Guidance recommends a minimum letter size (x-height) of 1.2 mm (equivalent to ca. 7 point depending on font selected).

The text should be horizontal when the container is set down normally.

The information should be structured to make it easy to understand, such as by grouping all hazard statements and precautionary statements together. However, there is no prescribed overall design for the label.

Increasing the area available for labelling

Normally the label is affixed directly to surface of the container, such as a bottle or drum. If the container is too small or too awkward in shape to accommodate the required information, then common solutions are to increasing the space for labelling by using fold-out labels, tie-on tags, or outer packaging.

Fold-out labels are a concertina design, with information contained within the folds. The part of the label that is affixed to the container should contain at least the following label elements: pictograms; the product identifier (but it is not necessary to show the hazardous ingredients for mixtures); and the name and telephone number of the supplier. These details should remain attached to the container if the rest of the fold-out label is torn away.

The ‘front page’ (ie the part on display on the container) should repeat this information, and in addition show: the name of the supplier; a phrase to indicate that further safety information is available in the fold-out section (eg safety information, see inside – this should be translated into all languages contained in the fold-out label, and be accompanied by the country code or language code); and the nominal quantity if sold to the general public.

A tie-on tag can be attached to the container by sturdy string, or wrapped around a small container to produce a flag on which labelling information can be placed.

Alternatively, the small container can be placed in a larger outer packaging. In this case, the outer packaging should display all the required information. The smaller inner container has to display as a minimum the pictograms, the product identifier, and the name and telephone number of the supplier.
The outer packaging option is useful for products that comprise several small containers such as chemical kits.

These methods, fold-out labels, tie-on tags, and outer packaging, should not be used where the lack of space is caused by the inclusion of non-mandated information, such as advertising, trade marks, or the addition of languages other than those Member States for which the product is intended.

Reducing the amount of text: concessions for small package labelling

Due to the extensive requirements for mandatory pictograms and text, the supplier can have difficulty fitting all the required information on the label.

The CLP Regulation has some concessions for smaller packages, acknowledging that the risk of harm to humans and the environment is reduced for smaller amounts of chemical.

The provisions for omitting label information from small packages are given in CLP Regulation, Article 29(2), which refers to the detail given in Annex I, 1.5.2.1.

For substances supplied at 125 mL or less, and classified in certain hazard categories, some of the information usually required on the label can be omitted, as summarised in Table 2.

Where the substance or mixture is classified under other hazard categories not listed, all of the label elements related to these other hazard categories must still be included on the label.

Hazard classification of the substance or mixtureAllowed omissions from the label
Physico-chemical classifications:
Oxidising Gas, Category 1; Gases under pressure; Flammable Liquid, Categories 2 or 3; Flammable Solid, Categories 1 or 2; Self Reactive, Types C to F; Self-Heating, Category 2; Contact with Water Emitting Flammable Gas, Categories 1, 2, or 3; Oxidising Liquid, Categories 2 or 3; Oxidising Solid, Categories 2 or 3; Organic Peroxide, Types C to F

Toxicological properties:
Acute Toxicity, Category 4 (if not supplied to general public); Skin Irritation, Category 2; Eye Irritation, Category 2; STOT SE, Categories 2 or 3 (if not supplied to general public); STOT RE, Category 2 (if not supplied to general public)

Ecological properties:
Aquatic Acute Toxicity, Category 1; Aquatic Chronic Toxicity, Categories 1 or 2.
Hazard and precautionary statements can be omitted, for these hazard categories.

Comment:
The pictograms and signal word are required.
Physico-chemical properties:
Flammable Gas, Category 2

Toxicological properties:
Reproductive Toxicity, Category 3 (effects on or via lactation)

Ecological properties:
Aquatic Chronic Toxicity, Categories 3 or 4.
Precautionary statements can be omitted for these hazard categories.

Comment:
The hazard statements and signal word are required, as these hazard categories do not have hazard pictograms.
Corrosive to metalsHazard pictogram, signal word, hazard and precautionary statements can be omitted for this hazard class.
Table 2: Elements of the label that can be omitted for small packages (<125 mL)

Figure 2 shows an example of the reduction in labelling text that can be achieved. An ethanolic solution with a hazard classification of Flammable Liquid, Category 2, Eye Irritant, Category 2, would require the labelling as shown on the left. For a container with capacity less than 125 mL, the derogations as listed in the above Table 2 allows the reduced labelling on the right.

Labelling of a hazardous product, showing the reduction of information for small packages.
Figure 2: Example of reduced labelling requirement for a small container

Special case exemptions from full labelling

Dishwashing tablets and similar packaged small products (but not biocides or plant protection products) with soluble packaging and a volume of < 25 mL do not require any hazard labelling, provided that they are supplied in a fully labelled outer container (eg box) and are classified in the hazard categories mentioned in Table 2 above.

Products intended for scientific research and development (but not biocidal products or plant protection products) with a volume of < 10 mL only require the product identifier and certain pictograms, provided that they are supplied in a fully labelled outer container.

Unpackaged goods that are classified as hazardous and sold to the general public should have the labelling information for the product provided at the time of purchase and also with the delivery of the product, if this occurs at a different time, eg on paperwork provided with the product. Note that this provision only applies to those products specifically listed in CLP Annex II, Part 5, currently only ready mixed cement and concrete in the wet state.

Labelling through layers of packaging

Under CLP there is a general requirement that all layers of packaging must be labelled with the CLP labelling information, unless a layer is transparent and the label below it is clearly visible.

However, where products are required to be labelled on the outer packaging according to transport regulations, there is a reduction in the CLP information that must be displayed:

  • Where the outer packaging for a combination package (ie one where individual containers are consolidated into a larger box, etc) are also labelled under transport of dangerous goods regulations [7], it is optional to include the CLP information on the outer packaging. Where the CLP information is included, the CLP pictograms may be omitted if they duplicate the transport labels.
  • For single packagings (ie those such as a drum that are not get consolidated into a larger package), both CLP and transport labels are required, although the CLP pictograms may be omitted if they duplicate the transport labels.

For a small package, these provisions that allow the CLP information to be omitted are very useful.

Conclusions

Products classified as hazardous under the CLP Regulation requires label elements such as pictograms, signal word, hazard statements, precautionary statements and supplemental information.

Correct labelling can be complicated, because several other Regulations can require additional text to appear on the label.

Often, the labelling information required by the legislation exceeds the available space on a small container.

The amount of space available for hazard labelling can be increased by using fold-out labels, tie-on tags, or outer packaging.

There are concessions for packages below 125 mL.

Even with these concessions it is often difficult to fully comply with all of the requirements. A company should make every effort to include mandated information on the label, and justify and document any decision to deviate from it.

References

[back to Label Elements] [back to Precautionary Statements] [back to Supplemental Information] [back to Detergents] [back to Aerosols] [back to Labelling Through Layers]

[1] The Chemicals (Health and Safety) and Genetically Modified Organisms (Contained Use) (Amendment etc.) (EU Exit) Regulations 2019; UK Statutory Instrument 2019 No. 720.

[2] Guidance on Labelling and Packaging in Accordance with Regulation (EC) No 1272/2008; ECHA; Version 4.1, May 2020.

[3] Globally Harmonized System of Classification and Labelling (GHS); Eighth Revised Edition; United Nations; 2019.

[4] Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures (as amended).

[5] Regulation (EC) No. 648/2004 of the European Parliament and of the Council of 31 March 2004 on Detergents (as amended).

[6] Council Directive of 20 May 1975 on the Approximation of the Laws of the Member States Relating to Aerosol Dispensers (75/324/EEC) (as amended).

[7] Recommendations on the Transport of Dangerous Goods – Model Regulations; United Nations; Twenty-First Revised Edition; 2019.

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