The CLP Regulation aims to protect users from the hazards posed by substances and mixtures. Certain types of packaging may however prove difficult to appropriately label, for example:
CLP provides certain exemptions for substances and mixtures contained in packaging that is small (typically less than 125ml) or is otherwise difficult to label. The exemptions allow the supplier to omit the hazard and/or precautionary statements or the pictograms from the label elements normally required under CLP.
As a general rule, the labelling or marking in accordance with transport legislation is sufficient when the outer packaging of a hazardous substance is subject to both the transport (ADR) and the CLP regulations. The CLP labelling does not need to appear. Similarly, when a hazard pictogram required by CLP relates to the same hazard as in the rules for the transport of dangerous goods, the CLP pictogram does not need to appear on the outer packaging.
Single packaging that meets the requirements for labelling under both the transport (ADR) and CLP regulations, must be labelled in accordance with both regulations. However, where hazard pictograms required under CLP are also required under ADR, the CLP pictograms need not be displayed.
Unpackaged substances and mixtures
Unpackaged materials may be supplied to professional users, whereby labelling information and other relevant hazard information is provided through other means than a label, usually the Safety Data Sheet. In exceptional circumstances, substances and mixtures may also be supplied to the general public unpackaged. In case the substance or mixture is listed in Part 5 of Annex II (currently only cement and concrete in the wet state), a copy of the labelling elements is always required, for example on an invoice or bill.
Tactile warnings and child-resistant fastenings
If substances or mixtures are supplied to the general public, then child-resistant fastenings and/or tactile warnings of danger have to be attached to their packaging where these substances or mixtures have certain hazard classes or if the packaging contains methanol or dichloromethane. These provisions apply regardless of the capacity of the packaging.
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