If your company manufactures, sells, or packages products containing hazardous substances or mixtures, sooner or later, there will be changes in the formulation or in the regulation on the classification and labeling of chemicals. Consequently, a key question arises: When can we keep the label as it is, and when does it need to be updated?
A label is not just bureaucracy - it is a legally binding document, providing the user with the first – and often most important – source of information about the hazards and safe handling of the product. Therefore, the label must always be accurate, clear, readable, and up-to-date.
What should a label contain?
A label for a product classified as hazardous must include:
- hazard pictograms,
- a signal word
- H-statements (hazard statements)
- P-statements (precautionary statements)
- EUH-statements (additional hazard information when prescribed)
- UFI code (unique formula identifier) for mixtures where required
- supplier contact details
- identifiers (trade name and hazardous substances if necessary).
All elements of the label must be clearly visible, readable, and properly arranged. They are specified in section 2.2 of the corresponding safety data sheet.
EUH-statements complement the hazard classification and warn of specific risks not covered by standard H-statements.
UFI code is mandatory for mixtures classified as hazardous to human health or posing a physical hazard. It enables precise identification of mixtures in cases of poisoning and must be clearly indicated on the label, consistent with the data submitted to Poison Centers and updated with every composition change that requires a new UFI code – as we have discussed here.
When should a label be updated immediately?
The supplier must ensure that the label is updated immediately following a change in the classification and labeling of the substance or mixture if the new hazard is more severe (e.g., from an irritant to a corrosive chemical) or if new additional label elements are required (e.g., UFI code, EUH statements) considering the type of change regarding the protection of human health and the environment. Suppliers must collaborate to change the labeling without delay.
When is the use of an existing label still allowed?
If the new hazard is not more severe, and the mandatory elements (including EUH-statements and UFI code) remain unchanged and the label is already compliant with legislation regarding content and format, it can continue to be used. The use of an existing label is therefore permitted if, for example, new precautionary statements (P-statements) are added to the new safety data sheet, if the supplier's address changes, or if the supplier's phone number is replaced.
In such cases, the CLP Regulation stipulates that the supplier must ensure the label change within 18 months.
What can you do yourself?
- Regularly check the compliance of labels and safety data sheets,
- ensure that labels contain all mandatory elements according to Article 17 of the CLP Regulation,
- pay special attention to EUH-statements and changes requiring a new UFI,
- be particularly attentive if the new hazard, as determined by the new safety data sheet, is more severe,
- update labels if necessary.
If you don't have the time or feel you can't handle the task, you can write to me at spela.hudobivnik@bens-consulting.eu and together we will find a suitable solution.
bojan.dimic@bens-consulting.eu
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