Compliance with Child Resistant Fastening and Tactile Labelling Requirements under CLP – ECHA Enforcement Survey
SAFEGUARDS | Consumer Products NO. 166/15
The CLP regulations cover labelling and packaging of hazardous substances and mixtures. For such substances and mixtures supplied to the general public, there are certain requirements for child resistant packaging and/or tactile labelling. The ECHA Enforcement forum is carrying out inspections in 15 member states to determine the level of compliance.
As part of the requirements of the Classification, Labelling and Packaging Regulation (CLP)  ((EC) No. 1272/2008) substances or mixtures supplied to the general public with specific classifications require packaging with child resistant fastenings, tactile warning or both.
The CLP regulation provides a list of hazard classifications for substances and mixtures which trigger a requirement for child resistant packaging and/or for tactile warning. Mixtures containing more than 3% Methanol or 1% Dichloromethane also trigger a requirement for child resistant packaging.
In June 2015, the European Chemicals Agency (ECHA) announced  that from July 2015 until the end of December 2015, inspectors in 15 member states are checking consumer products containing hazardous substances or mixtures requiring child resistant packaging. Typical products include lighter fluids, disinfectants, cleaning and laundry products as well as drain cleaners.
According to the CLP regulation, suppliers are required to label a substance or mixture contained in a packaging when
- A substance is classified as hazardous or
- A mixture contains one or more substances classified as hazardous above a certain threshold concentration.
The content of the label and the arrangement of the labelling elements are defined under Article 17 of the CLP Regulation. The label includes:
- The name, address and telephone of the supplier
- The nominal quantity of a substance or mixture in the package made to the general public
- Product identifiers
- Single word (Warning or Danger)
- Where applicable, hazard pictograms, hazard statements, precautionary statements and supplemental information
Besides child resistant packaging/containers, the inspectors are also checking the packaging for tactile warnings and to ensure that there is no confusion with foodstuff, animal feed, medicine or cosmetics.
According to the CLP regulation, the technical specifications for tactile warning devices shall conform to EN ISO 11683 as amended ‘Packaging — Tactile warnings of danger — Requirements’.
The inspections are mainly targeted at formulators, re-importers, re-fillers and re-packagers of mixtures intended for the general public, and importers of mixtures. In addition, distributors (including retailers) and manufacturers that sell substances intended for the general public are being inspected.
Packaging of laundry detergent capsules may also be subject to these inspections. Specific requirements for labelling and packaging of these capsules were also established in Regulation (EU) 1297/2014 , an amendment to the CLP regulation. These are increased resistance to pressure, slower dissolution, and presence of a bittering agent with a repulsive effect if a child puts the capsule in its mouth. The requirements for the outer packaging are opacity, and the presence and clear visibility of the precautionary statement “Keep out of reach of children”, as well as child resistant fastening (the coordinated action of both hands is required to open the packaging).
A report on the findings of the inspectors will be published by the Enforcement Forum - the Forum for Exchange of Information on Enforcement in June 2016.
Throughout our global network of laboratories, we are able to provide a range of services, including analytical testing and consultancy, for CLP labelling and Safety Data Sheets (SDSs) for the European and international markets. Please do not hesitate to contact us for further information.
For enquiries, please contact:
Dr Andrew Kassyk
Senior Product Integrity Engineer
t: + 44 1274 303080
Corporate Research & Development
t: + 852 2204 8339 ext 1339
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