What is CLP?

The Classification, Labelling and Packaging (CLP) Regulation ((EC) No 1272/2008) is based on the United Nations’ Globally Harmonised System (GHS) and its purpose is to ensure a high level of protection of health and the environment, as well as the free movement of substances, mixtures and articles. The CLP Regulation amended the Dangerous Substances Directive (67/548/EEC (DSD)), the Dangerous Preparations Directive (1999/45/EC (DPD)) and Regulation (EC) No 1907/2006 (REACH), and since 1 June 2015, is the only legislation in force in the EU for classification and labelling of substances and mixtures. Although we are no longer part of the EU we have adopted all the legislation passed from the EU, and we still need to have CLP to be legally compliant. If you are also selling within the EU from January 2021 you will also need to have UFI numbers on your CLP.

 

CLP is created using the product identifier and information from section 2 on the manufacturers safety data sheet, also known as an SDS or MSDS sheet. The allergens within the fragrance only needed to be listed if they are above elicitation levels, you can check the data of each chemical on the C&L inventory held by ECHA. The chemicals needed to be listed at the % used are listed greatest first. There is no set format for listing precautionary statements but as the chemicals are listed greatest first, the relevant statements for the strongest chemical are listed first and any additional statements for the other chemicals are listed after, there is no need to repeat the same precautionary statement. Some SDS sheets state similar sentences that mean the same thing, remember to add the exclamation pictogram if required. You can also omit statements that don't apply to your end product, for example its very hard to get the fragrance from a melt into your eye so you may decide that you do not need to include the statement IF IN EYES: rinse with water for several minutes....., but a room spray or a diffuser where there is liquid that could be sprayed or splashed in the eyes would be wise to keep the statement in. We also find that many CLP are created by machine that keep in unnecessary statements such as personal protective equipment must be used, although when handling the raw chemicals you would need to use personal protective equipment it is not necessary for someone to handle a melt or candle, this is because the chemicals are diluted and also trapped in the wax so are less harmful than the full 100% chemical. There is no legal requirement for which statements need to be added to the CLP you need to use your common sense as to which are necessary and which can be safely omitted. It is wise to keep any documentation of any statements omitted and your reason why, in case you ever need this information in an emergency. Its best to keep it in your file of SDS sheets of your fragrances which you need to keep for your records. The statement regarding disposal of the product should always be on your CLP or safety information as a matter of good practice. You also need to work out the toxicity to aquatic life which is accumulative, from all the chemicals on the SDS sheet find out the level of toxicity to decide if the CLP needs to be harmful to aquatic life or Toxic to aquatic life, If its toxic it will also need to have the red warning pictogram.

 

It is very worth while learning as much as you can about CLP rather than relying on what supplied by your fragrance suppliers, this will ensure you can spot any mistakes or errors in the CLP, we have found many CLP that have not been done correctly or have errors. I will try to cover some basic advice on how to check if your CLP is correct in another article. If unsure always ask your supplier, they should be able to get the information from the person who has created the CLP for them.

Choosing the right CLP size

I get asked lots of times what size should I have my CLP, and so I thought I'd put down these few thoughts and guidelines to help you decide.
Firstly you need to consider the size of your product, if it is over 125ml then you must use regulation sizes the smallest size we have closest to the smallest regulation size is 63x72mm. If a rectangle sticker can not fit because you have a hard to label product or your product is smaller than 125ml then you need to consider these to determine the appropriate size.
1) Although regulation covers rectangle stickers only it is widely accepted that circle stickers are the most convenient shape for candles and melts
2) You must choose the biggest size that will fit your product, just choosing the smallest size to get economical sticker prices will not ensure you comply as fully with regulation as possible.
3) The CLP must be easily readable when the product is in its correct position, however it is widely accepted that CLP can be bigger if it is stuck to the base. This should only be done though if there is no other option but to have the CLP there.
4) Before you order your CLP take a look at the information required in it, the more complex the CLP the more text may needed to be included and so a bigger sticker should be chosen. 
5) 45mm and 50mm are by far the most popular round sticker sizes, however you need to remember that these are not covered by regulation, the text and pictigrams may not be regulation size if too much text is needed. If you require safety to be added to the CLP this will also compromise pictogram and text size. This is why you need to choose the biggest size.

I hope this helps you to better understand how to choose a CLP size, if yu are still unsure just contact us for some help and guidance.