The design of a label based on the requirements of the CLP Regulation
Explanation of the key requirements of Regulation (EC) No 1272/2008 (CLP Regulation) for the design of monolingual labels on the basis of an example.
The exemplary label includes the labelling elements required by Article 17, letters a-h of the CLP Regulation for a hazardous mixture being placed on the market. This also includes the nominal quantity although the mixture is not intended for the general public.
The mixture is not classified in one of the four new EU hazard classes. It is therefore not labelled with “EUH statements” that function as “H-statements” (main hazard statements).
Minimum dimensions and minimum sizes
The label is intended for a container with a capacity of a volume of 1 l. With its capacity, the container therefore belongs to a package of up to 3 l (see Annex I, Part 1, point 1.2.1.4, Table 1.3 of the CLP Regulation). In the original version, the hazard pictograms were created in the required minimum dimensions (no smaller than 16 mm x 16 mm). However, due to the considerable number of labelling elements the label is bigger than the minimum size specified in the CLP Regulation. Their size has therefore been adjusted so that each pictogram takes up less than 1/15 of the label area. This is admissible, as long as the respective minimum sizes are complied with.
The hazard and precautionary statements are listed in blocks and are separate from the obligatory supplementary label element. In the original version, the font size is at the lower readable limit (1.2 mm x-height). If further supplementary label elements have to be placed on the label, irrespective of whether such elements are obligatory or not, the label is to be enlarged to the required size. When this is done, the size of the hazard pictograms may remain the same.
The precautionary statements shown on the label were chosen according to the Guidance on Labelling and Packaging in accordance with the CLP Regulation. According to Article 28(3) of the CLP Regulation, the label should include a maximum of six precautionary statements (combined precautionary statements count as one precautionary statement). Whereas in our example there are eight statements. This is due to the severity of the hazards that may arise from the mixture.