In industrial and commercial practice, one of the recurring problems is placing the full CLP labelling on the product label when it is sold in small packaging. The CLP Regulation specifies certain minimum sizes for labelling elements, such as pictograms, on labels – which we discuss in more detail in this article: CLP Update: New Requirements for Label Legibility

The issue of limited label space affects many products, especially when multiple languages are required, but the most significant challenge by far is the labelling of small packages. These difficulties have become even more pronounced with the recently published update of the CLP Regulation.

So how can one deal with the labelling of products where the packaging is too small to accommodate the required information? This is where the labelling exemptions provided for in the CLP Regulation come into play.

Labelling Exemptions – CLP Regulation

The following analysis of possible technical solutions for labelling small packages is based on the updated text of the CLP Regulation. Currently, the deadlines for applying the new rules are still under discussion, and the final shape of the regulation may change (as we discuss in this article: Will the CLP update be postponed?). For the purpose of this analysis, however, we assume that the provisions on exemptions from labelling contained in Regulation (EU) 2024/2865 apply and can already be used.

Fold-out Labels

The use of fold-out labels is not an exemption per se, but rather one of the technical labelling methods. It is worth noting that prior to the update of the CLP Regulation, this solution was reserved only for very small packages, whereas now the use of fold-out labels is also permitted for larger products, and the technical requirements have been incorporated directly into the regulation (previously, guidance on the use of such labels could only be found in the CLP guidance document and were not legally binding).

This solution is particularly useful where multilingual labels are needed, since combining them with other exemptions may not be possible. For multilingual labels, however, it works very well, because the front side of the label does not need to include all languages – these must be placed on the inside pages.

Exemption for Packages Below 125 ml

The exemption for packages with a volume below 125 ml derives from Article 29(2) of the CLP Regulation and is a partial exemption. It allows omitting hazard statements and precautionary statements related to certain hazard categories, including for:

• Flammable liquids, Category 2 or 3
• Substances or mixtures causing skin irritation, Category 2
• Substances or mixtures causing eye irritation, Category 2
• Substances or mixtures hazardous to the aquatic environment – chronic, Category 1 or 2

This means that if a product is classified as skin irritant (H315) and respiratory sensitiser (H334), one can omit the H315 statement and its related precautionary statements, while the H334 statement and its associated precautionary statements must remain.

It is important to note that this exemption does not allow omitting the relevant pictograms or other mandatory elements such as the product identifier or supplier details.

As mentioned – this is a partial exemption, which can be useful when a small product is classified in several hazard categories, some of which fall under the exemption. In justified cases, part of the text can then be omitted.

Exemption for Very Small or Difficult-to-Label Packages

The exemption for very small or difficult-to-label packages stems from Article 29(1) of the CLP Regulation and allows for a broader omission of labelling elements compared to the 125 ml exemption. In this case, it is possible to omit all hazard (H) and precautionary (P) statements, as well as supplemental information, on the label of the immediate/inner packaging, provided that all elements required under Article 17 of the CLP Regulation are included on:

• A tag attached to the package
• The outer packaging

In this case, the label on the immediate (inner) packaging must still contain:

• Pictograms
• Signal word
• Product identifier
• Supplier name and telephone number

This solution provides greater flexibility but requires the supplier to use an additional outer packaging or a hangtag that will contain the full labelling.

Exemption for Packages Below 10 ml

This exemption changed in scope with the update of the CLP Regulation and is now the broadest exemption available. Its application is particularly relevant in the following cases:

1. When the substance or mixture does not require labelling in accordance with Part 1 or 2 of Annex II (EUH statements) and has not been classified in specific hazard categories (the CLP Regulation lists all hazard classes excluded here – essentially those considered to pose serious concerns for human health and safety, such as corrosivity, acute toxicity, or respiratory sensitisation).
2. When the substance or mixture requires labelling in accordance with Part 1 or 2 of Annex II (EUH statements), but has not been classified in any of the hazard classes and categories referred to in point 1, and the inner packaging is placed within an outer packaging that meets the requirements of Article 17.

This means that for products with a “low” classification and packaged in containers below 10 ml, it is possible to omit labelling entirely if the relevant conditions are met.

Summary

As mentioned at the beginning, placing the required CLP labelling elements on product labels can be challenging, particularly for small packaging. However, the CLP Regulation also provides technical solutions, the application of which may help overcome these challenges, provided that the specific requirements are met.

If you are unsure which exemptions can be applied to your products – contact us, and we will help you choose the most optimal solution.