Individual CLP pictogram labels

Some label companies are offering individual CLP pictograms (or symbols), that is the diamonds with the red border, white background and black hazard symbol, as individual labels for sale.

Strictly speaking, this is not allowable under CLP, as all of the CLP information should be placed on the label.

This may be due to confusion between CLP pictograms and Transport symbols, as the latter are often used individually.

It could also be due to the situation under CHIP where people often used symbol substrates pre-printed with two orange boxes, and if the product had an applicable third symbol, it was added as an individual symbol label.  The third symbol was for environmental hazard (“dead fish, dead tree”).

However, CLP does not operate to the same rules and practices as either Transport or CHIP, and the full CLP label should include all of the CLP pictograms, and they should probably not be used.

In situations where e.g. you import a product with a GHS label from the USA which requires the environmental hazard pictogram for the EU, you wouldn’t just need the pictogram: you’d also need to add in appropriate H and P statements, and unless you had a separate label for that information as well, just adding the pictogram would not be sufficient to describe the hazards.  So it would be better to re-do the label for the EU.

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