Tactile Warning of Danger (TWD) – Requirements and Standards
What is a Tactile Warning of Danger?
A Tactile Warning of Danger (TWD) is a specific requirement under the CLP Regulation, where—in addition to labelling obligations—there are also packaging-related provisions. It is a packaging element (either integrated into the packaging or applied as an additional sticker) in the form of a raised triangle that is detectable by touch and thus serves as an additional warning for blind or visually impaired individuals. It provides an alternative way to convey hazard information to people who cannot read the CLP label text.
When is a Tactile Warning of Danger required?
The use of this technical element on packaging is required under the CLP Regulation for products that meet the following conditions:
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They are supplied to the general public
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They are classified in one or more of the following hazard classes:
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Acute toxicity
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Skin corrosion
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Germ cell mutagenicity (category 2)
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Carcinogenicity (category 2)
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Reproductive toxicity (category 2)
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Respiratory sensitisation
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STOT (Specific Target Organ Toxicity) category 1 or 2
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Aspiration hazard
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Flammable gases
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Flammable liquids (category 1 or 2)
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Flammable solids
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For all products which CLP label contains hazard statements corresponding to any of the above categories, the use of a TWD is mandatory.
Are there exemptions from the TWD requirement?
As outlined above, the tactile warning of danger is not required when:
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Products are not supplied to the general public (e.g., professional-use paints)
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Aerosol products classified solely as aspiration hazards (unless also classified in one of the other listed hazard categories
In all other cases, the use of a TWD is mandatory. Failure to include it on the packaging of a chemical product will be considered non-compliance, potentially resulting in administrative penalties and the need to withdraw the product from the market.
How to correctly apply a TWD?
The method for applying a TWD is described in the standard EN ISO 11683: "Packaging – Tactile warnings of danger – Requirements."However, it is usually not necessary to study the standard in detail, as compliant packaging with built-in tactile markings is widely available, and adhesive raised triangle stickers meeting the TWD requirements can also be purchased.
What does this mean in practice?
🔴 Verify whether your products require a tactile warning of danger – it’s best to do this during the product design stage, as this allows for the appropriate packaging to be selected
🔴 The absence of a TWD constitutes a serious regulatory breach and may require you to retrieve the product from customers in order to update or modify the packaging
Summary
Using a TWD is a legal obligation under the CLP Regulation. It applies only to certain hazard classes and only to consumer products. It plays a crucial role in ensuring hazard communication for blind and visually impaired individuals.
Unsure whether your mixtures require a TWD?
Contact us – we’ll help you assess the requirements.
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