What changes does the CLP Regulation update bring to labels?
With the entry into force of Regulation 2024/2865, several changes affect labels:
• List of substances in the “contains” section of mixtures:
In addition to the names of mixture components responsible for classification due to certain human health effects, the CLP Regulation update requires the inclusion of substances that contribute to the classification based on persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB), persistent, mobile and toxic (PMT), very persistent and very mobile (vPvM) properties, or endocrine-disrupting properties for human health or the environment.
• Supplementary information:
The supplier may include additional supplementary information in the appropriate section of the label, provided it does not make it harder to identify the label elements and offers clarifications that do not contradict or undermine the validity of the mandatory information.
Furthermore, label elements required by other pieces of Union legislation must also appear in the section reserved for supplementary information.
• Label update with strict timelines:
If a change in the classification or labeling of a substance/mixture leads to the addition of a new hazard class, a more severe classification, or the need for new supplementary information, the supplier must update the label without undue delay.
- The CLP update has clarified the timeframe of this “undue delay” by stating: “and in any case within 6 months of obtaining the information.”
- However, if the change is due to a harmonized classification and labeling of a substance under a delegated act, the supplier must ensure the label is updated by the date set in the respective delegated act.
• Mention of the EU supplier on the label:
A supplier established in the EU must always be identified on the label, even if the product is purchased by a private individual through an online store.
• Element sizes:
In relation to the packaging capacity, minimum dimensions must be respected not only for the label and pictograms but also for font size and line spacing.
• Text layout:
The label must have the following features:
a) printed in black on a white background;
b) spacing between lines of at least 120% of the font size;
c) use of a single, easily legible sans-serif font;
d) sufficient spacing for easy readability based on the chosen font.
We answer one of our clients’ most frequent questions
Q: One of my labels includes several pictograms and many H and P statements. According to the new rules, I don’t have enough space. What should I do? Have the pictogram sizes changed? Can I make them smaller?
A: Table 1.3 of Annex I to the CLP has been updated and now includes not only minimum sizes for labels and pictograms but also font sizes, based on packaging capacity.
Note that a new packaging capacity range has been introduced: for containers up to 0.5 L. For these, minimum sizes have been defined for the label, pictograms, and font size (respectively in mm: 52 x 74 for the label, at least 16 x 16 per pictogram—reducible to 10 x 10 for small labels—and 1.2 mm font size).
Aside from this, the content of Table 1.3 has not changed from the previous version.
Possible solutions if it is not feasible to print all required elements on the label:
- Check if the packaging capacity is below 125 ml, as this may allow for certain information reductions under Article 29 points 1 or 2;
- Consider using a larger label;
- Consider adopting a fold-out label or a hanging tag.
