clp labeling and packaging guidelines - cepsa

HSSEQ | Product Stewardship

CLP Labeling and Packaging Guidelines

Version 0, March 2020


March 2020

Introduction

This document is intended for the persons responsible for marketing Cepsa Group packaged products. Before placing them on the market in the European Union, the substances and mixtures that are marketed in packaging must be properly labeled in accordance with the provisions of the CLP Regulation.

The CLP Regulation addresses:

• The classification • Hazard warnings on the labeling • Packaging requirements for hazardous products.

It is aimed at employees and consumers, and covers the supply and use of chemical substances/mixtures.

It does not cover the transport of chemicals. However, Article 33 of the CLP lays down certain rules concerning the labeling of containers also used for transport.

The transport classification is covered by the Framework Directive (2008/68/EC) implementing the European Agreement on the International Carriage of Dangerous Goods by Road (ADR), The Regulations on the International Carriage of Dangerous Goods by Rail (RID) and the European Agreement on the International Carriage of Dangerous Goods by Inland Waterways (ADN).

And for chemicals with specific legislation?

The CLP regulation covers substances and mixtures in general. For certain chemicals such as phytosanitary products, or explosives precursors, the labeling elements required by CLP can be supplemented by those required by their specific legislation.


March 2020

Should samples sent to clients be labeled according to CLP?

According to CLP, products placed on the market must be properly labeled. Marketing is understood to mean the supply of a product, or its provision to a third party, either by payment or free of charge. Therefore, samples sent to our clients must be labeled according to CLP.

Should samples sent to internal Cepsa laboratories be labeled according to CLP?

The CLP regulation does not require samples sent to internal laboratories to be labeled because it is not considered to be provision to a third party, but Cepsa recommends that they be labeled as a matter of good practice.

Should samples sent to external R&D laboratories be labeled according to CLP?

According to Article 1 of the CLP, substances and mixtures intended for research and scientific development are excluded from the scope of this regulation, but Cepsa recommends that they be labeled as a matter of good practice.

What does the classification, labeling and packaging of hazardous substances consist of?

A substance or mixture may be hazardous depending on its potential to cause harm. It depends on the intrinsic properties of the substance or mixture. Where the nature and severity of a detected hazard meet the classification criteria, hazard classification is the assignment of a standardized description of this hazard of a substance or mixture that is harmful due to its physical properties or its effects on human health or the environment.

Once these properties are identified and the substance or mixture is subsequently classified, the manufacturers, importers, intermediate users and distributors of substances and mixtures, as well as the producers and importers of certain specific articles, must inform other agents along the supply chain, including consumers, of the identified hazards of such substances or mixtures. Hazard labeling warns users of the hazard classification of a substance or mixture to alert them to the presence of a hazard and the need to manage the associated risks. The CLP regulation lays down general packaging rules to ensure the safe supply of hazardous substances and mixtures.


March 2020

And the risk assessment?

The classification of a substance or mixture reflects the type and severity of the intrinsic hazards of that substance or mixture. It should not be confused with the risk assessment, which refers to a specific risk from the actual exposure of humans or the environment to the substance or mixture presenting such a hazard.

At Cepsa, who provides the guidelines for the Classification, Packaging and Labeling of our products under CLP?

The Product Stewardship Division is responsible for conducting the CLP Classification of our products and for notifying the ECHA (European Chemicals Agency) of this classification. When required, it also advises on the contents and sizes of the CLP label and the type of packaging. These responsibilities are described in the following Corporate Procedures:

�PR-237. Product Safety Information in the Cepsa Group. �PR-300. Procedure regarding Explosive Precursors, Drug Precursors, and Chemical Weapons �PR-301. Definition of Products and Preparation of Specifications �PR-306. Procedure for Product Stewardship in the Cepsa Group


March 2020

How is labeling done?

� Labels shall be firmly affixed to one or more surfaces of the packaging immediately containing the substance or mixture (Article 31 of the CLP).

� They shall be readable horizontally when the package is set down normally.

� Labels must be of minimum size in relation to the volume of the container.

Label sizes (and pictogram) as defined in Annex I, paragraph 1.2.1, to the CLP

Capacity of the package

Dimensions of the label (in mm)

Dimensions of each pictogram (mm)

Up to 3 liters

If possible, at least 52x74

Not smaller than 10x10

If possible, at least 16x16

Greater than 3 liters but not exceeding 50 liters

At least 74x105

At least 23x23

Greater than 50 liters but not exceeding 500 liters

At least 105x148

At least 32x32

Greater than 500 liters

At least 148x210

At least 46x46

Labeling information can be displayed on the product packaging itself instead of having a label (e.g. sacks). This means that the labeling information can be printed directly on the packaging itself, rather than sticking a label containing this information onto the packaging. However, all labeling requirements described in this guide must be met.


March 2020

What information should appear on the label?

If the substance or mixture has to be labeled and contained in a container, it must include the labeling elements in accordance with Article 17 of the CLP:

� The name, address and telephone number of the provider or providers of

the substance or mixture; � The nominal quantity of the substance or mixture contained in the

packaging to be provided to the general public, unless this quantity already appears on the other side of the packaging;

�Product identifiers; and, where applicable: - hazard pictograms; - relevant warning wording; - hazard indications; - appropriate precautionary statements; - supplementary information.

The labeling elements must be clearly and indelibly marked on the labels. Ensure that they stand out clearly from the background and are large and separated for easy reading.

Information required by other legislation, such as information required by legislation on phytosanitary products or explosives precursors, may also need to be included on labels.

Specific labeling requirements are set out in Annex I, paragraph 1.3, to the CLP. These apply to (Article 23 of the CLP):

�Transportable gas cylinders; �Gas containers intended for propane, butane or liquefied petroleum gas; � Aerosols and containers fitted with a sealed spray attachment and

containing substances or mixtures classified as presenting an aspiration hazard;

� Metals in massive form, alloys, mixtures containing polymers, mixtures containing elastomers;

� Explosives, as referred to in section 2.1 of Annex I, placed on the market with a view to obtaining an explosive or pyrotechnic effect;

� Substances or mixtures classified as corrosive to metals but not to the skin or eyes.


March 2020

What is the UFI?

The unique formula identifier, known as the UFI, is a 16-character alphanumeric code that must appear on labels for mixtures that have health and/or physical hazards.

It is used in order to provide health authorities with product information in the event of a toxicology emergency.

What language(s) should the label be written in?

The label shall be written in the language(s) of the Member State or States in which the substance or mixture is placed on the market, unless otherwise provided for by the Member State or States concerned.

In general, more languages than those required by the Member States may be used, provided that all of them have the same information (Article 17(2) of the CLP) and that the label continues to meet the easy-to-read requirement (Article 31 of the CLP).

Languages required on safety data sheets and labels

Country:

Language 1

Language 2

Language 3 Austria German

Belgium 1) French Flemish German Bulgaria Bulgarian

Croatia Croatian

Cyprus Greek Czech Republic

Czech

Denmark Danish Estonia Estonian

Finland Finnish Swedish

France French Germany German

Greece Greek

Hungary Hungarian Iceland Icelandic

Ireland English


March 2020

Country:

Language 1

Language 2

Language 3 Italy Italian

Latvia Latvian

Liechtenstein German Lithuania Lithuanian

Luxembourg German 2) French 2 )

Malta Maltese English

The Netherlands

Dutch

Norway Norwegian Poland Polish

Portugal Portuguese

Romania Romanian

Slovakia Slovak

Slovenia Slovenian

Spain Spanish Sweden Swedish

Switzerland 3) German French Italian United Kingdom

English

Examples of labels:

Supplier ID

Product ID

Warning word contains:…

Precautionary statements sorted by language

Pictogram


March 2020

Prod

uct

iden

tific

atio

n Pi

ctog

ram

Si

gnal

w

ords

Haz

ard

stat

emen

ts

Prec

autio

nary

St

atem

ents

so

rted

by

lang

uage

Supp

lier

ID


March 2020

What if the packaged product is transported?

This is the case with combined labeling:

If the label must meet both the requirements of the CLP regulation and the standards for the transport of hazardous goods (ADR, RID, ICAO, IMDG), it will be necessary to verify, depending on the packaging layers, whether CLP labeling is required, or labeling (or marking) for transport, or both (Article 33 of the CLP).

Examples:

Product identifiers that include

substances that are used to classify the

mixture as toxic with acute effects, repeated exposure STOT and toxic by

aspiration

UNXXXX [Appropriate shipping name]

Hazard Highly flammable liquid and vapors. Toxic when in contact with the skin. Causes skin irritation. May irritate the airways. May cause damage to the liver and testicles after prolonged or repeated exposure. May be fatal if ingested or enters airways. Very toxic to aquatic organisms, with lasting harmful effects. May cause drowsiness or dizziness.

Keep away from heat, hot surfaces, sparks, open flames and any other ignition sources. No smoking. Wear gloves, protective clothing and goggles. IF INGESTED: Call a POISON CONTROL CENTER/doctor immediately. DO NOT induce vomiting. Avoid release into the environment. Dispose of the container at the municipal collection point.

See the safety data sheet for details on safe use.

Manufactured by

Company X, Street Y, Locality Z Zip Code 00000 Tel.: +49(0)0000000000

TOXIFLAM (Contains X, Y) UFI: VDU1-414F-1003-1862

Supplier ID

Space for additional

information (e.g., user instructions)

Precautionary statements

Hazard statements

Signal word

Transport labeling

CLP hazard pictogram UFI code

Product identifier

March 2020


Envae •nd1111dua l con tiquetado dtr1.1nsportle.••

-·e informatiOn de- diqud.e:do ClP

So

CLP v

March 2020


When should labels be updated?

The supplier shall ensure that the label is updated, without undue delay, following any change to the classification and labeling of that substance or mixture, where the new hazard is more severe, or where new additional labeling elements are required under Article 25 of the CLP (Article 30 of the CLP). This also includes non-classified mixtures containing at least one substance classified as hazardous.

Where other labeling elements are required, for example, when the revised classification is of lower severity or the telephone number has changed, it must be guaranteed that the label be updated within 18 months.

Are there exemptions to labeling requirements?

Where the packaging of a substance or mixture has such a form or is so small that the requirements cannot be met, they shall be provided by means of drop-down labels, hanging labels or outer containers. If even then it is impossible to meet the labeling requirements, the label information can be reduced according to certain conditions specified in the CLP. In these cases, contact the Product Stewardship Division.

Are there CLP standards for packaging hazardous substances and mixtures?

Article 35 of the CLP includes requirements for containers containing hazardous substances or mixtures. These provisions are intended to ensure that: � Packaging is designed, constructed and sealed in such a manner that the

contents cannot escape; � The contents must not deteriorate materials for the packaging and

sealing, nor must these materials be likely to form hazardous compounds with the contents;

� Packaging and sealing must be resistant and solid in all parts so that they do not loosen;

� Packaging with reusable seals must be designed to be closed repeatedly without the contents escaping;

� Packaging must not attract or arouse the curiosity of children or lead to error on the part of consumers when supplied to the general public;

March 2020


� Packaging does not have an appearance similar to, or a design used for, food products, animal feed, medications or cosmetics, which could mislead clients.

Packaging meeting the requirements of the transport legislation is also considered to comply with the requirements set out in the above points (however, it should be noted that meeting only the conditions set out in the above points is not generally sufficient to meet the requirements of transport legislation).

In the case of substances and mixtures supplied to the general public, the CLP regulation lays down rules for: � The use of safety seals for children; � The use of tactile warnings of danger (TWD).

These provisions are activated by a specific hazard class or category, or by the concentration of specific substances contained in other substances or mixtures. The Product Stewardship Division shall provide information about such provisions when necessary.

Bibliography

This guide is based on the following references:

� Regulation (EC) No. 1272/2008 on the classification, labeling and

packaging of substances and mixtures: https://eur-lex.europa.eu/legal-content/ES/TXT/PDF/?uri=CELEX:32008R1272&from=ES

� Introductory Guide to the CLP Regulation:

https://echa.europa.eu/documents/10162/23036412/clp_introductory_es.pdf/b312ecb3-0299- 4d52-86f0-b151cfe674ac

� ECHA. Guidance on labeling and packaging in

accordance with Regulation (EC) No. 1272/2008: https://echa.europa.eu/documents/10162/23036412/clp_labelling_es.pdf/dd0fc071-c3a4-444b- bd85-5b55f2659d12

clp labeling and packaging guidelines - cepsa

Documents