Updated chemical labeling rules: New requirements for font size, letter dimensions, and label legibility

Chemical labeling regulations are evolving to enhance safety and ensure critical information is effectively communicated.

Recent updates to the Classification, Labeling and Packaging (CLP) Regulation (EU 2024/2865) introduce significant changes to labeling requirements.

This article outlines the key changes and what manufacturers, suppliers, and distributors need to know to maintain compliance. 

New minimum font size requirements 

The updated CLP Regulation introduces specific minimum font size requirements to ensure the legibility of hazard information on chemical labels.

Base measurement 

The lowercase letter "x" height must be:

• at least 1.2 mm (for capacity of the package not exceeding 0,5 litres) 
• at least 1.4 mm (for capacity of the package greater than 0,5 litres but not exceeding 3 litres)
• at least 1.8 mm (for capacity of the package greater than 3 litres but not exceeding 50 litres)
• at least 2.0 mm (for capacity of the package greater than 50 litres  

Enhanced Readability Standards 

Beyond font size, the updated regulations also address: 

• Contrast and legibility: Text must maintain high contrast against the background
• Permanence: Label elements must remain legible throughout the product's normal use 
• Language requirements: Information must be provided in the official language(s) of the Member State(s) where the substance or mixture is placed on the market 
• Spacing and formatting: Adequate spacing between lines and clear formatting to enhance readability 

Label Durability and Visibility 

The regulation emphasizes that labels must: 

• Remain securely fixed to the packaging
• Be visible from multiple angles 
• Withstand normal handling conditions 
• Resist fading, discoloration, or deterioration that could reduce readability 

Digital Labeling Supplements 

While physical labels remain mandatory, the regulation now acknowledges digital supplements: 

• QR codes or similar technologies can provide additional information
• Digital elements cannot replace mandatory label information 
• Additional language versions or detailed safety information can be provided digitally 

Implementation Timeline 

The updated regulations introduce a phased implementation approach: 

• Entry into force: December 2024
• Mandatory use for products which will be placed on the market after 1 January 2027: deadline 1st January  
• Mandatory use for products which will be placed on the market before 1 January 2027: deadline 1st January 2029  

Substances and mixtures which have been classified, labelled and packaged in accordance with “OLD CLP Regulation” which were placed on the market before 1 January 2027 shall not be required to be classified, labelled and packaged in accordance with NEW CLP Regulation until 1 January 2029.

Supplementary Label Elements 

The regulation introduces new requirements for supplementary label elements: 

• UFI (Unique Formula Identifier): Must be clearly visible and legible
• Use of multiple languages: When multiple languages are used, information in each language must be grouped together 
• Precedence of mandatory information: CLP mandatory elements take precedence over other regulatory labeling requirements 

Label Placement and Organization 

The updated regulation emphasizes the importance of strategic label placement: 

• Readability without manipulation: Information should be readable without needing to manipulate the package
• Pictogram positioning: Hazard pictograms must be placed together and remain unobstructed
• Hierarchical information: More severe hazards must be prominently displayed 

Industry Implications 

These changes will significantly impact manufacturers, suppliers, and distributors: 

• Label redesign: Existing labels will need to be reviewed and potentially redesigned
• Packaging considerations: Product packaging may need adjustments to accommodate larger text
• Compliance costs: Companies should anticipate costs related to label redesign and implementation
• Supply chain communication: Ensure all partners in the supply chain are aware of these requirements 

Preparing for Compliance 

Organizations should take these steps to prepare: 

1. Audit current labels: Review existing labels against the new requirements 
2. Develop implementation plan: Create a timeline for updating labels before deadlines
3. Train staff: Ensure relevant personnel understand the new requirements 
4. Consult with experts: Consider engaging regulatory experts to ensure compliance 
5. Update systems: Modify label production systems to accommodate new specifications 

Conclusion 

The updated CLP Regulation reflects a continued focus on ensuring that hazard information is clearly communicated to users of chemical products.

By establishing specific font size and legibility requirements, regulators aim to enhance safety across the supply chain. Organizations should begin preparing now to ensure smooth compliance with these new requirements. 

For more detailed information on the new regulations, consult the official text of EU Regulation 2024/2865 or contact your regulatory compliance advisor.