Products which are supplied to consumers have specific requirements over and above those for professional and industrial users. These requirements may include:
- P statements for consumers
- Tactile Warning Labels
- Child Resistant Packaging
- No need to supply a consumer with a Safety Data Sheet
- Small packaging label information
- Other packaging requirements for consumer products
- Advertising hazardous products to consumers
Other specific consumer products may have different obligations, such as detergents (see https://ttenvironmenta.wpengine.com/clp-knowledgebase/detergents/), or laundry liquitabs (see https://ttenvironmenta.wpengine.com/clp-knowledgebase/laundry-liquitabs/).
P statements for consumers
There are three P statements which are only applicable to consumer products (where relevant):
- P101, If medical advice is needed, have product container or label at hand.
- P102, Keep out of reach of children.
- P103, Read label before use.
These are not generated by any specific hazard, and it is up to the person classifying the product to decide whether they should be applied to the label.
Also, under Article 28 of CLP, consumer products always require a P statement addressing the disposal of the product and its packaging (unless the CLP-GHS classification does not generate any P statements relating to disposal). The potential P statements for disposal are P501, Dispose of contents/ container to … (most hazards), or P502, Refer to manufacturer/ supplier for information on recovery/recycling (only applies to H420 hazardous to the ozone layer).
Tactile Warning Labels
Consumer packages may require tactile warning labels, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/tactile-clp-labels/ . Note that tactile warning labels are not required for products which are only supplied to professional or industrial users.
Child Resistant Packaging
Consumer packages may require child resistant packaging, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/child-resistant-fastenings/. Note that child resistant fastenings are not required for products which are only supplied to professional or industrial users.
Tactile labels and child resistant packaging do not match exactly, and one or both may be required, depending on the hazards of the product, see Hazards triggering tactile warnings and child resistant fastenings .
Safety Data Sheets are not supplied to consumers
Safety Data Sheets are not supplied to consumers, because they are intended to provide a professional or industrial user with information to help them protect the health of their workers.
However, if a professional or industrial user who has been supplied with a consumer product requests an SDS, one must be provided, although there is no timescale given in the regulations to do this. This type of request may either come from a customer who has purchased the product, or from someone who handles it on your behalf, such as transport and warehousing companies. There is no requirement to supply an SDS to someone who has not physically received the product, e.g. a consultant who is working on your behalf.
Small packaging label information requirements for consumer products
The label derogations for small packages are given here: https://ttenvironmenta.wpengine.com/clp-knowledgebase/small-package-labelling/ .
However, it should be noted that:
- these derogations only apply to the initial package, and overpacks will require full CLP labelling
- consumer products can only use some of the 125ml derogations, not all of them, and the 10ml derogations do not apply
General packaging requirements for consumer products
Packaging containing a hazardous product supplied to the general public shall not:
- Have a shape or design likely to attract or arouse the active curiosity of children
- Mislead consumers, and in particular have a similar presentation or design to foods, animal foods, medicines or cosmetics
Advertising hazardous products to consumers
Before purchasing a CLP classified product, consumers must either have sight of the label, or be informed of the hazards of the product. For more details see https://ttenvironmenta.wpengine.com/clp-knowledgebase/selling-and-advertising-clp-products/ . This applies to both face to face and post and internet sales.