Small package labelling

Under CLP (and GHS), it is permitted to have smaller labels (sometimes containing less information) on:

• all packages between 125 ml and 3 litres
• all packages between 10 ml and 125 ml
• industrial and professional use packages for QC and R&D purposes less than 10 ml

Notes:

• the sizes refer to the volume of the package, not the volume of the product
• consumer packs are not allowed to use the derogation at less than 10 ml size, and must have the information at 10 ml to 125 ml as a minimum
• even though information can be omitted from the label for the individual package, the full labelling information is still likely to be required for any outer packages containing the small packs, so you need to be aware that you may need more than one label for different package sizes of the same product

The minimum label size for packs less than 3 litres is A8 paper size, that is 52mm x 74 mm.

If you have space to place a CLP label of this size on your less than 3 litres pack, you should do so.  These reductions in size or information required on the label are intended for situations where there is not space for the full-sized label expected under CLP.

Packages from 125 ml to 3 litres

If the label cannot meet the minimum size requirements, and the pack is greater than 125 ml, there are four options available:

• Fold-out labels
• Tie-on tags
• Peel off labels, but note that the information under the peel off label must be fully CLP-compliant, including using a red pictogram border (this has been checked with the HSE helpdesk by a client), and all of the CLP information must be placed together under the peel off label, just like on a normal CLP label.  At the time of writing, 20th February 2018, it may not be possible to source a supplier who can produce a peel-off label with a red border for any pictograms.
• Use the full information on the “outer” package, in which case the “inner” package labels must contain this information:
  • Hazard pictograms
  • Product identifiers
  • Name and tel no of supplier

Note that where inner and outer packages are referred to, this means an individual outer package, e.g. a bottle inside a cardboard box.  The bottle can have minimum information, but the outer box must contain the full information.

Packages less than 125 ml

At this size of package, if space does not allow all of the information to be placed on the CLP label, some information can be omitted for certain hazard classifications for all types of packages less than 125 ml.  A further seven classifications where information can be omitted for industrial and/or professional use (but not from consumer).  However, more severe hazards still require full information on the package label.

All packages less than 125 ml: Hazard info omittable from all packages less than 125 ml v1.1 04-07-2017

Industrial and professional packages less than 125 ml: Extra hazard information also omittable from industrial or professional packages less than 125 ml .

There is also a further derogation for QC or R&D samples, which does not apply to consumer packages.

Industrial and professional user packages less than 10 ml, QC or R & D samples only

Limited labelling is allowed on inner packaging for industrial and professional user packages where:

• The contents on the inner package do not exceed 10 ml
• and the substance or mixture is placed on the market for supply to a distributor, or downstream user for R&D or QC purposes
• and the inner packaging is contained within outer packaging that meets normal CLP labelling requirements (i.e. it has a full CLP label).

Note that this derogation is NOT allowed for plant protection products regulated under 91/414/EC or biocidal products regulated under 98/8/EC (or its successor the Biocidal Products Regulation).

The limited labelling comprises:

• The product identifiers (either substance name and identity number, or mixture trade name and “contains” information)
• The following symbols if classified as such:
  • GHS01 (explosive)
  • GHS05 (corrosive)
  • GHS06 (toxic)
  • GHS08 (health hazard)
  • If more than two of these specific symbols are required, GHS06 and GHS08 may take precedence over GHS01 and GHS05