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CLP

Hazard communication with means other than labelling

What kind of information must be provided in an advertisement for hazardous substances according to CLP Article 48?
CLP Article 48(1) outlines the information which must be provided in an advertisement for a substance classified as hazardous. The advertisement shall contain the hazard class and/or the applicable hazard categories, as appropriate, e.g. acute oral toxicity category 3.
What kind of information must be provided in an advertisement for mixtures according to CLP Article 48(2)?

CLP requires that where a member of the general public can purchase a mixture without first seeing the label, and where that mixture is classified as hazardous or contains a hazardous substance as referred to in CLP Article 25(6), then the advertisement for that mixture must mention the type or types of hazard as indicated on the label.
The type of hazard is best specified by providing the relevant hazard statements, including the supplemental hazard statements as referred to in CLP Article 25(6). It is also recommended that the hazard pictograms and signal word are mentioned, where appropriate, to alert the reader to a potential hazard.

For sales to the general public, it is not sufficient nor relevant to refer to a safety data sheet containing this information.

Can transport labels be included in Section 2.2 of the SDS?

No, Section 2.2 of the SDS is intended only for supply (CLP) pictograms, which are described in Annex V to the CLP Regulation. The transport labels can be included in Section 14 of the SDS (see also Annex II to REACH).

Where the inner packaging of a chemical product requires a tactile warning to be fitted, does the outer and intermediate packaging also require a tactile warning?

No, only the inner packaging is required to be fitted with the tactile warning. 

The technical specifications of the tactile warning are given in EN ISO standard 11683 (section 3.2.2.2 of Annex II to CLP). The ISO standard states that ‘... the tactile warning shall be placed on the packaging and not on any secondary packaging, such as cardboard box protecting a glass bottle, so that it can be felt prior to fully opening the package'. The warning shall also remain tactile during the expected period of use of the package under normal handling conditions. 

Thus, the ISO standard provisions aim to ensure that when handling a chemical product the person who has a visual disability is aware of the danger. The ISO standard refers to ‘primary packaging', which can be understood as ‘inner packaging' in CLP terminology.

Outer and intermediate packaging may be fitted with the tactile warning but this is not obligatory.

Does the scope of Article 48 of CLP include internet sales through websites and web shops?

Yes, a web page can be regarded as an advertisement in the scope of Article 48. Hazard information must be provided in this type of advertisement for classified and labelled substances, in accordance with Article 48(1). 

When a member of the general public can conclude a purchase of a mixture online, without first having sight of the label, the information required by Article 48(2) must be provided. 

How should the meaning of “general public” be understood in the context of Article 48(2) of CLP?
The term "general public" is understood in this context to mean anyone who is not buying the chemical for their professional activities. This would be equivalent to ‘consumers’ in the context of this provision.

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