QA1724

Yes, they do. All substances and mixtures that fulfil the criteria for classification as hazardous in accordance with the CLP Regulation are subject to the labelling requirements of CLP. For example, where the ink used in a pen is classified as hazardous, that will lead to labelling obligations. 

Where the ink reservoir is a fixed component of the pen or marker as it is placed on the market, the pen/marker needs to carry the appropriate labelling. If full labelling is not possible, then the exemptions set out in Article 29 and points 1.5.1 and 1.5.2 of Annex I to CLP can be used. 

In the case of empty (blank) pens and re-fillable pens, the pen body does not need to be labelled, as the body of the pen is an article which is not the container of the ink. The hazards depend on the ink used in the replaceable ink cartridge or refill, which need to fulfil the labelling requirements of CLP.