The EU CLP digital label is about to be introduced and implemented!
Time:
2024-05-09
The EU CLP digital label is about to be introduced and implemented!
The European Commission approved a new proposal on the classification and labeling of EU chemicals (EC No 1272/2008) on April 23, 2024 (P9-TA (2024) 0296). After further review and confirmation by the European Council, it was published in the official daily newspaper of the European Union and came into effect within 20 days from the date of publication.
This revision aims to align with the digital age and enhance consumer product security, with a focus on the concept of "digital tags" and other requirements.Overview of revision points:
01 Introduction of digital labeling system
According to Article 31 of the CLP regulation, the labels of substances and mixtures should be firmly affixed to one or more surfaces of the packaging directly containing the substance or mixture (i.e. "physical labels"). In order to comply with the trend of the digital age and in accordance with Article 290 of the Treaty on the Functioning of the European Union (TFEU), the new regulation advocates the introduction of digital labels in chemical management.
Suppliers attach or print links to digital labels through data carriers, with specific requirements as follows:
(1) A data carrier refers to a linear barcode symbol, QR code, or other automatically recognized data capture medium that can be read by the device; The EU CLP introduces digital tags, which can also provide the content of tag elements in digital form (i.e. "digital tags").
(2) Digital labels can be pasted or printed on physical labels or packaging next to the labels;
(3) It is also possible to provide label elements only on digital tags and attach a "More hazard information available online" statement or similar explanation on the "data carrier".
(4) Suppliers are required to comply with a series of standards when providing digital labels, including:
a. All label elements should be concentrated in the same location and distinguished from other information;
b. The information on digital tags should be easy to retrieve;
c. The information on the digital tag should be accessible to all EU users and should remain accessible for at least 10 years or longer as required by other EU legislation;
d. Digital tags should be provided free of charge, without the need to register, download, or install applications, or provide passwords;
e. The presentation of information on digital tags should simultaneously meet the needs of vulnerable groups and make necessary adjustments in relevant situations to facilitate the access of special groups to information;
f. The information on the digital tag should be accessible with no more than two clicks;
g. Digital tags should use universal digital technology and be compatible with all major operating systems and browsers;
h. When the information on a digital tag can be accessed in more than one language, the choice of language should not be limited by the geographical location where the information is accessed.
02 Shorten label update time limit
If the chemical classification is updated to a stricter classification, new classification is added, or new information is required, the supplier needs to complete the label update within 6 months, which greatly shortens the label update time compared to the previous requirement of 18 months.
03 Refine label specifications
For hazardous chemicals, especially cleaning products, specific specifications for labels, illustrations, and font size have been added;
Introducing foldable label design to enhance practical flexibility.
04 Update the list of endocrine disruptors and other substances
The new proposal clearly states that substances with new classifications such as endocrine disruptors, PBT/vPvB, PMT/vPvM, etc. will be included in Annex 6 of the CLP.
For example, substances with endocrine disrupting properties that are currently included in the candidate list under Article 59 (1) of Regulation (EC) No 1907/2006 should be listed as "Endocrine disrupting class 1 to human health" or "Endocrine disrupting class 1 to the environment" in Table 3 of Annex VI of the CLP.
05 Specification for Advertising Requirements for Hazardous Chemicals
Any advertisement classified as a hazardous substance or mixture should indicate its corresponding hazard pictogram, signal word, hazard statement, and EUH statement.
Any advertisement for substances sold to the public should also state: "Always read and follow the information on the product label."
The new CLP regulations strictly prohibit the use of misleading statements such as "non-toxic," "harmless," and "pollution-free" in advertisements for hazardous chemicals solely for promotional purposes.
06 Clarify MOC substance classification assessment
The classification evaluation of substances containing more than one component (MOC substances) should be comprehensively evaluated according to the same classification rules as the mixture, to ensure that they can be classified as hazardous based on the component and the substance itself.
Meanwhile, for MOC substances extracted from plants, specific components considered in isolation may have hazardous characteristics that may not be expressed throughout the substance. Therefore, the committee will propose complete relevant legislation based on further scientific evidence.
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