Revisions to CLP Legislative Act passed in EU Parliament

GHS CLP label changes update passes in eu parliament

 

European Parliament validates agreement with EU Council on changes to classification, labelling and packaging of chemicals regulations.

In a decisive vote held on 23rd April, the EU CLP Legislative Act received overwhelming support from MEPs, with 533 in favour, 11 against, and 65 abstentions.

The passing of this vote confirms the text agreed between the co-legislators and ushers in substantial changes to chemical label formatting and minimum font sizes, as well as the broader use of digital labels and booklet labels.

Credit to Janet Greenwood of TT Environmental Ltd for providing early access to the ‘Partial Legal-Linguistic Finalisation’ text. This text will not change substantively before publication and is available to download here: TA-9-2024-0296_EN

Ensure to read the small print very carefully before deciding if/how this applies to your business – to be completely certain, you may want to wait for the pdf version.

 

New Label Formatting Rules

The new formatting rule for labels are:

  • The text must be printed in black and the background of the text should be white;
  • A single font must be used that is easily legible and without serifs;
  • The letter spacing must be appropriate for the selected font to be comfortably legible;
  • The distance between two lines must be equal, or above, 120% of the font size – for example, a 20 point size font must have leading (line spacing) of 24 point, or above;
  • The font size of regulatory information must be as the following table, dependent on package capacity.

GHS CLP minimum font sizes table points 2024

 

Label Elements Affected by the Minimum Font Specifications

  • Hazard Statement(s)
  • Precautionary Statement(s)
  • Supplemental information
    • EUH Statement(s)
    • Information relevant to other Union Acts (such as Plant Protection Products, Biocidal Products or Detergents
    • Supplemental information that the supplier opts to include that doesn’t contradict the other information on the label
  • Nominal quantity
  • Name, address and telephone number of the supplier
  • Product identifiers
  • Signal Words

 

Implications for Chemical Labelling

These regulatory adjustments will have significant ramifications for chemical labelling in the EU, affecting areas such as chemical classifications, hazard notifications, and label layout requirements. The acceptance of minimum font sizes, line spacing, and colour contrast, as well as the utilisation of digital and booklet labels, are among the key changes to be addressed.

The following shows a 74x105mm label, for a 3 lite pack size, before and after the format changes are applied. The new minimum font sizes and line spacing means that all of the necessary elements can not be fitted on the label for a product with a standard amount of information meaning many products will have to be labelled at a larger size.

ghs clp label font sizes not fitting on label 2

Changes to Deadlines for Updating Information on Labels

As well as changes to the labelling elements, the Commission also published proposals regarding fixed time periods for updating labels:

  • After a change to the classification or labelling: If the classification becomes more severe, or new supplemental information is added to the label, the supplier must update the labels without undue delay – and no later than 6 months.
  • For any other change to the classification or label, the label must be updated without undue delay – and no later than 18 months.
  • If any changes are triggered by a harmonised classification covered by an ATP, then the date(s) specified in the ATP take precedence.
  • If the label falls under the biocide or detergent regulations then any specified timeframe within those regulations take precedence.

 

Implementation Deadlines

It should take a maximum of 8 weeks before the text is published in the EU LEX and transition dates for updating the information on labels to the new requirements are as follows:

For new products:

    • Updating labels after a change of classification: 18 months after this regulation appears in the Official Journal – EU LEX.
    • Rules for advertisements: 18 months after publication.
    • All label formatting rules (including minimum font sizes) may still be subject to change in the finalised text but we are currently expecting: 24 months after publication.

For products already on the market with label formatting as the existing legislation in the 2 years following EU LEX publication, then it’s fine for 4 years after EU LEX publication.

For products already on the market where the label elements need to change (because of the the changes to the ‘contains’ statement, or the addition of the Endocrine hazards, PBT or PMT classes) then the timescale is shorter – around 3.5 years (See Article 61 for more details).

If the label falls within the biocide or detergent regulations, then it is the timeframe specified  within those regulations take precedence.

 

Previous Related Posts

EC Proposes major overhaul of chemical labelling

CLP proposed label changes Novermer Updatre

Understanding the changes to CLP label minimum font sizes

 


How Can Hibiscus Help?

Hibiscus Plc has been providing labelling solutions for the chemical and hazardous goods industries for over 40 years.

If you have any questions regarding the new minimum font sizes for labels, don’t hesitate to contact us.

Find out how we can improve your label compliance – Call us today: 0113 242 4272

enquiries@hibiscus-plc.com