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SDS | December 3, 2018

Laundry washing capsules are liquid household detergents kept in single-use soluble packaging, because when in contact with water the capsules dissolve.

They can be purchased at almost any household cleaning agents shop department. They enable simple use without the need to measure and determine the used detergent quantity, because the capsule content is ready for a single laundry washing cycle. If used correctly, the user does not get in direct contact with the detergent, because the capsule can be simply put directly in the washing machine, and the user only sets the desired washing programme.

Have you perhaps noticed that there are frequently no warning signs on capsules, such as pictograms, hazard sentences (H-statements) and precautionary statements (P-statements)? This is not necessarily wrong, because the Regulation on classification, labelling and packaging No. 1272/2008 (CLP) permits this is in certain cases.

Such exclusions are considered as exemptions. Two conditions must be met for exemptions in labelling.

The first condition refers to labelling with regard to the type of hazard of a chemical or content. In other words, the type of hazard stipulates when the label elements on internal packaging (capsule) can be left out and when not.

Let's see when the internal soluble packaging (capsule) must be labelled? A label is necessary if the content of soluble packaging is categorised among the substances with the following health hazards:

  • skin and eye corrosion (H314, H318),
  • specific target organ toxicity at single or repeated exposure (H370, H371, H335, H336, H372, H373),
  • aspiration toxicity (H304),
  • acute toxicity for human health (H300, H310, H330, H301, H311, H331, H302, H312, H332),
  • respiratory or skin sensitivity (H334, H317) and
  • carcinogenicity, mutagenicity and reproductive toxicity (H350, H351, H340, H341, H360, H361).

In all other cases referring to health hazards, label elements on the capsule can be left out.

Let's have a look at an example.

If the capsule content is categorised as human health hazard, indicated in the above list (e.g. H318), the capsule itself must also be labelled.

If the capsule content is categorised as a hazard that is not indicated in the above list (e.g. H319), only the external packaging must be labelled. Internal soluble packaging, i.e. capsule, therefore does not have to be labelled.

Besides the above-mentioned health hazards, there are also environment hazards as well as physical and chemical hazards.

Detergents in capsules are usually not categorised under the mentioned hazard categories, therefore, I have not indicated exceptions with regard to labelling.

The second condition
for leaving out the label elements on internal packaging (capsule) is the packaging itself. At product packaging, the provisions for capsules and for external packaging must be considered:

  • Capsule content may not exceed 25 mL.
  • The wrapping must contain a bittering agent which in case of oral exposure causes vomiting in 6 seconds.
  • The capsule must contain the liquid content for at least 30 seconds after getting in contact with water (at 20°C).
  • It must be resistant to mechanic compressive force of 300 N or more.
  • External packaging, in which capsules are held, must be non-transparent and self-standing; it must also enable simple multiple closure, disabling small children to open it.
  • External packaging must also preserve its functionality during its whole life period.

The labelling of capsules may be completely left out, if the above-mentioned conditions are considered. However, the external packaging must still contain all the mandatory label elements.

External packaging must contain:

  • pictograms,
  • signal word,
  • identifier (the name of the hazardous substance, if necessary),
  • hazard statements (H-statements) and
  • precautionary statements (P-statements).
  • The precautionary statement P102 "KEEP OUT OF THE REACH OF CHILDREN" (we recommend using bold and capitalised letters, the size or colour of letters can be changed) must be indicated at a visible place and in the form attracting attention.

Let me sum up how to appropriately label laundry washing capsules.

If the capsule content is categorised as a less hazardous chemical and the capsule content does not exceed 25 mL, the label on the capsule itself is not necessary. Despite this, all hazard-related information must be indicated on the self-standing external packaging that prevents children from opening it. A special feature here is the method of indicating the P102 precautionary statement – "KEEP OUT OF THE REACH OF CHILDREN". It is recommended that this sentence is indicated in the form that immediately attracts attention (e.g. bolded, in capitals etc.).

Disclaimer:
Information on this blog is prepared with utmost care, but it is not about (chemical) consulting, and the provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can write to us at bojan.dimic@bens-consulting.com

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