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BENS Consulting

BENS Consulting

BENS Consulting is a chemical regulatory consulting company that helps companies in the chemical industry fulfill regulatory requirements and leverage digitalization to improve related business processes.

Lobbying Activity

Response to Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products)

3 Sept 2021

I welcome any initiative to simplify and streamline labelling requirements, especially in connection to digital labelling. However, we must keep in mind that the labelling of chemicals in the EU is regulated by CLP Regulation, which should be based on UN’s Globally Harmonized System (aka GHS). However, the idea of global harmonization turned to be utopian since we now have a CLP (EU version), OSHA (US version) and GHS, which is (more or less) used in other regions. Therefore, radical changes to CLP cannot be done unless GHS changes as well (I assume). Another thing that we must keep in mind is that in the EU, we have 27 countries with different official languages. As a result, producing multilingual labels requires a substantial surface on the label and packaging. Anyway, I would suggest the following steps to simplify and streamline labels and labelling: First: there is still room for improvement within the current legislation. For example, there is an article 28(3) of the CLP that says: “Not more than six precautionary statements shall appear on the label, unless necessary to reflect the nature and the severity of the hazards.” Yet, despite this provision, we often see ten or more (even up to twenty) precautionary statements on labels. If companies followed this provision or selected the statements more wisely, they could save up to 50% of the space on a label. Second: the requirements for detergents, fertilizers and other groups should be reduced to a minimum and focused on the most important properties that users find useful or relevant. For example, I don’t know anyone (except experts) to understand what it means to have 5-15% of anionic, cationic, or amphoteric surfactants in a detergent. Is this really relevant to consumers? Also, chemical names of allergens don’t really add to chemical safety. So instead, we should only label “contains allergens” or “contains allergens below/above cut-off limit” – but this is already included in the EUH statements. A good example of simplification is the labelling of VOCs for paints and coatings. It requires a little space and provides relevant information. However, a question is if it’s actually relevant to consumers since suppliers cannot sell products that exceed VOC limits. Third: digital labelling – in terms of “See additional information online”. Speaking from the practical experience: We first introduced “digital labelling” (in the form of QR codes on a label) to our customers back in 2012. The QR code on a label points to the respective product site on the web. From the product site you can access the product overview page, the safety data sheet (current and all previous versions, in all languages), the label and product safety instructions in all available languages. This solution proved to be very effective and efficient to many of our clients since they can put additional product information online where interested downstream users and consumers can find product details. Therefore, the product website could be used to provide product-related information – like detergents ingredients, allergen lists, fertilizer information, the latest safety data sheet, etc. – to downstream users and consumers. However, some aspects should be regulated. For example, the additional information should not be buried somewhere on the website but must be easily accessed and clearly visible – e.g. on the page displayed following scanning of the QR code. Also, the QR code on the label should be clearly printed and big enough to scan, etc. Last but not least: training! For consumers, training should be provided in school. In Slovenia, our kids already learn about hazardous chemicals. For professionals, a special training, with a focus on hazardous chemicals must be provided on a regular basis.
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