Classification, Labelling and Packaging (CLP)

Are your advertisements and website compliant too?

We all know the importance of Classification, Labelling and Packaging (CLP) on your product packaging, but did you know you also need to put it on any advertisement or website selling the product to be compliant?
Don’t get caught out!

Recital 67 of CLP (EC) 1272/2008 on CLP of substances and mixtures states: “Rules should be laid down requiring advertisements for substances meeting the criteria for classification set out in this Regulation to mention the associated hazards, in order to protect recipients of substances, including consumers. Advertisements for mixtures classified as hazardous that allow a member of the general public to conclude a contract for purchase without first having sight of the label should mention the type or types of hazard indicated on the label, for the same reason.”

Article 48 of CLP (EC) 1272/2008 on CLP of substances and mixtures states:
“1. Any advertisement for a substance classified as hazardous shall mention the hazard classes or hazard categories concerned.
2. Any advertisement for a mixture classified as hazardous or covered by Article 25(6) which allows a member of the general public to conclude a contract for purchase without first having sight of the label shall mention the type or types of hazard indicated on the label.”

What is the issue?
Who does this concern?
What does this cover?
Why this is important?
How does it work?
What is the issue?

This guide is designed to give you an introduction to the labelling of finished liquids and component products such as flavours, bases, shots and short-fills.

While this guide is compact and clear it goes into as much detail as required so you have a good understanding of the regulations which must be adhered to when your products are placed on the market in Europe and the United Kingdom.

Who does this concern?

Everyone involved in the manufacture, import, distribution or sale of liquids, flavours, bases, shots and short-fills should be aware of these regulations. In addition, this guide is for owners and operators of stores who require an easy-to-use option to help control the marketability of their goods.

What does this cover?

This guide covers; CLP (Classification, Labelling and Packaging), REACH (Registration, Evaluation, Authorization and Restriction of Chemicals), and EU TPD.

Why this is important?

While the Tobacco Product Directive (TPD) has previously been exclusively related to liquids containing nicotine, the additional CLP-Regulation and REACH- Provision require the additional information found in this guide.

How does it work?

The product to be labelled is assigned to a corresponding product type in the assessment diagram. The corresponding sample label in the product category shows the required label components. The significance of the individual components, as well as their presentation and content requirements, will be described in the section Labelling Elements. The General Information contains additional relevant regulations that needs to be complied with. If needed, the sources of the corresponding passages may be taken from the underlying legal texts.

Your next step

To discuss how CLP affects your product range and find out how to keep your products on the market in Europe and the United Kingdom, please contact ADACT as soon as possible.

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