At the end of 2024, the EU released a major update to the CLP Regulation (Regulation (EC) No 1272/2008). Although the changes were originally expected to take effect on January 1st 2027, the implementation of some provisions has now been pushed back to January 1st 2028.
Among other updates, this revision introduces new rules governing how chemical labels must be designed. While we are eagerly awaiting more detailed guidance, we have already prepared practical instructions to help you prepare compliant labels now.
In the past, labels needed to be legible — the size of the label itself and hazard pictograms were regulated, but text font size was not specified. From now on, the new rules set a minimum font size for label text (specifically, the “lowercase x-height”).
Moreover, this requirement scales with the volume of the packaging — meaning that the label layout must be adjusted depending on how big the container is.
Beyond the minimum font size, the revised CLP labelling rules introduce four additional mandatory criteria for printed text on chemical labels.
1. Text must be printed in black on a white background
This ensures maximum contrast and clarity, avoiding confusion caused by coloured or patterned backgrounds.
2. Line spacing (leading) must be at least 120% of the font size
In practice, this rule often causes the most difficulty. There are currently two possible interpretations:
Line spacing 1
Spacing based on the defined lowercase x-height — e.g. if “x” height is 1.2 mm, the line spacing should be minimum 1.44 mm.
Line spacing 2
Spacing based on the overall font size (Y) — the spacing must be at least 120% of Y.
Until official guidance clarifies which approach is accepted, it’s wise to plan for adequate vertical spacing between lines so that there’s clear visual separation (e.g. between the descender of one line and the ascender of the next).
3. Only a single, easily readable sans-serif font may be used
Serif fonts (such as Times New Roman) are not allowed because their small decorative strokes reduce readability — especially on small or compact labels.
4. Letter spacing (kerning/tracking) must allow the font to remain legible
Letters should not be compressed or too close together. Tight spacing reduces readability, especially under varying printing conditions or at small sizes.
For producers, importers, and distributors of chemical substances or mixtures, this means:
- Review your existing labels now — even if the rules formally apply from January 1st 2027 or January 1st 2028, early compliance is recommended.
- Verify that your labels meet the new font-size, spacing, and readability criteria — this may require redesigning label templates, especially for smaller packaging.
- Use a clear sans-serif font and ensure sufficient letter and line spacing.
- Use a high-contrast colour scheme: black text on a white background.
- Ensure layout scales appropriately with packaging volume — font and spacing should adjust depending on container size.
If you have additional questions regarding chemical labelling, feel free to write to me at simona.miklavcic@bens-consulting.eu.
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