CLP Labels – Do You Need A Tactile Warning of Danger?

The CLP/GHS symbols have changed over time and depending on where in the world you are and the exact regulation what’s shown may differ. In the EU a tactile warning has been required on these products for many years. In 2015 a tactile warning of danger was introduced posing challenges to the packaging companies supplying labels for these products.

The answer to the question “do I need to apply a tactile warning of danger label to my product?” isn’t straightforward. Yet, one simple question can help guide you. Could this hurt someone if used in an unintended manner? Is it intended for general retail? If yes then you should investigate your legal requirements further.

CLP Categories triggering tactile warnings of danger

For corrosive labels, we have had some clear guidance.

“a corrosion rate on either steel or aluminium surfaces exceeding 6.25mm per year at a test temperature of 55C when tested on both materials.” Source: UNECE. That said to have to display the image the product doesn’t have corrode metal, being able to corrode skin or damage eye-sight will see the product need the symbol.”

While doing a little reading for this we found this public draft from Europa explaining what categories need tactile warnings and the CLP labels.

Heres the full link for you: https://echa.europa.eu/documents/10162/13564/clp_labelling_packaging_guidance_v20_draft_peg_en.pdf”

A packaging of whatever capacity must be fitted with TWD for substances or mixtures classified for:

  • acute toxicity (category 1-4)
  • skin corrosion (category 1A, 1B and 1C)
  • germ cell mutagenicity (category 2)
  • carcinogenicity (category 2)
  • reproductive toxicity (category 2)
  • respiratory sensitisation
  • STOT (categories 1 or 2)
  • aspiration hazard (category 1)
  • flammable gases (category 1 and 2)
  • flammable liquids (category 1 and 2
  • flammable solids (category 1 and 2)

Displaying my Tactile Warning of Danger

To dispel one myth that keeps coming to us, a tactile warning symbol is not required on the outer packaging but is required on the handling surface of the primary packaging. So a carton, cardboard box protecting a bottle does not need a tactile warning label/print.

What is less clear is how these warnings should be displayed below is one place you can read ISO 11683 full, warning you can only read them by paying for it and were not allowed to copy and paste it here, we can, however, talk you through label & packaging implications over the phone.

Here’s the link: https://www.iso.org/obp/ui/#iso:std:iso:11683:ed-2:v2:en

And here’s a summary for you:

About Tactile Triangles & EN ISO 11683 (2017)

    • Present on handling surface – not removed in use
    • Appear as an Equilateral Triangle:
      • 16-20mm long 1.5-1.9mm thick
      • 8-10mm long and 0.8-1.2mm thick
      • Solid 3-4mm triangle
      • 0.5mm Dots between 4-9mm apart centre to centre
      • Not required on outer packaging
    • Not placed near embossed surfaces that could cause confusion
    • Remain tactile throughout product life
  • Packaging with a base
    • Tactile Placed On upright surface
    • Apex of triangle within 50mm of bottom or near as possible or lid if there is no bottom
  • No base: Tubes/cartridges
    • Placed on the shoulder around tube or nozzle.
    • Aerosols placed where the finger is placed to operate the spray
  • Full opening: Twisty top
    • As near as possible to the opening

Labels and Tactile Warnings Of Danger

Luckily getting a label with a tactile warning symbol on is easy. Two solutions are available; first, have a warning symbol integrated into the label and this is done using a screen print this can also be done on multi-layer labels. Secondly, have your label printed then attach the triangle with one of our clear labels that have triangles printed on so you can still read any text underneath.

One caveat to these tactile warnings is that you cannot thermal print over the top of them. So when specifying where they are placed don’t position them over any area where you may look to print on later.

Readability has the knowledge, ability and technical capacity to help you meet the standards needed for these regulations so call us to talk through the options and keep onside with the law.

Please note we don’t carry out any testing for CLP or make recommendations for having specific symbols displayed. You will have to find a laboratory that offers “CLP TESTING SERVICES”

EN ISO 11683 & Sweeden

Adding to complications different nations seem to enforce/interpret the guidelines differently. One customer who sells through the EU is only being told to put them on his products sold in Sweeden.