This article about BS ISO 11683 is intended to help you decide whether your products need to carry a tactile danger warning. If you have any concerns about complying with the ISO 11863 standard, about tactile warning labels or about what action is required to stay compliant, please contact us.
Do you ever feel that the stream of European legislation and standards in the packaging and labelling sector is never ending? Or that “red tape” only makes the lives of manufacturers, distributors and retailers ever more complicated?
Whilst at Readability we believe legislation has an important role to play within the labelling industry, we do sometimes wonder how effectively changes are communicated and how practical terms rules are enforced.
The guidance notes and supporting documentation for Labelling and Packaging are not the easiest information in the world to digest!
Take BS EN ISO 11683:1997 as an example. Is anyone other than label manufacturers aware of what this legislation actually entails?
What is ISO 11683?
For those of you not fully conversant with ISO 11683, it is the standard set out to protect blind or visually impaired people when handling packaging for substances and preparations that could be potentially harmful or dangerous.
Such products are required to be labelled with a tactile warning of danger – a raised equilateral triangle.
Two options are available:
- Tactile warning triangle can be supplied in rolls
as a transparent clear label and applied over the
printed label which is already on the packaging.
- The tactile triangles can be integrated into the label to create a more aesthetically pleasing and easier to apply tactile warning label.
On smaller packaging, the danger warning triangle can comprise three raised dots forming the point of a triangle.
How do I know if my products require tactile warning labels?
Interesting question! And not one that’s easy to answer by searching online! Most information sources will simply state that ISO 11683 covers any products sold directly to the public that are classified as:
- Very toxic
- Extremely flammable
This includes aerosol products propelled by butane, all of which require a tactile warning label.
Dig a little deeper and you might come across the table on the ECHA (European Chemicals Agency) website which outlines the Hazard Criteria and whether a tactile label is required.
How do I know if my product falls under one of the classifications?
This really depends on your role in the supply chain.
If you are a manufacturer or importer of chemicals you must classify, label and package your products appropriately before they go to market. You are also responsible for adding your substance to the Classification and Labelling (C & L) Inventory which is managed by the European Chemicals Agency (ECHA).
Notifying the C & L Inventory is not required if you are further down the supply chain and you:
- Formulate other products from substances supplied
- Refill them into different containers, or
- Re-import them.
However you still have a duty of care under the Classification, Labelling and Packaging (CLP) Regulation and must ensure that your products are correctly classified and accurately labelled.
Under the CLP Regulation, sellers and distributors of chemicals, such as retailers, who only store and sell on the chemical to consumers, can rely on the classification information that they have been given by their supplier.
Bear in mind though, if the chemical is changed in any way before it goes to market, the seller or distributor becomes responsible for classifying, labelling and packaging the chemical.
What products are covered by ISO 11683?
You might be surprised at the range of products that fall under the BS EN ISO 11683:1997. From stylish e-cigarette liquid cartridge refills to more mundane bottles of glue, and from ant killer to household cleaning products – the legislation is more far-reaching than you might think.
Rule of thumb: everyone in the supply chain has a responsibility to ensure that a substance or mixture is labelled and packaged correctly before it goes to market.
If you are not sure what your responsibility is, contact us and we’ll be pleased to help.
Who enforces ISO 11683?
In the UK, Local Trading Standards Authorities are responsible for policing the legislation. Their aim is to help businesses to trade legally.
Many local authorities offer detailed guidance notes for those involved in the manufacture and distribution of these potentially harmful and dangerous products.
Any last advice?
If you’re concerned about your responsibilities under the BS ISO 11683 legislation, our advice is to:
- Make yourself as aware as you can about the legislation and your responsibilities
- Work closely with your supply chain
- Ask your local Trading Standards Agency for further information
- Choose an expert supplier in the labelling industry.
That way, you will have all the bases covered.
For any other questions about BS ISO 11683 or any other legislation around labelling, please call us on 01440 712 273. With decades of experience in labelling, lots of happy customer and the right quality credentials we have the expertise to help.