FEATURE
CLP AND LABELLING:
A BRIEF UPDATE
By Damian Bove, CEO, ADACT Medical
There are changes to the Classification, Labelling and Packaging
(CLP) Regulation that came into force this December, and I see a
lot of companies are not fully compliant yet.
It all stems from the classification of nicotine. Previously there were
no harmonised standards and manufacturers were able to set their
own classifications, as long as they could justify it, so you had lots of
different uses of exclamation and skull and crossbones symbols.
(In the image, you’ll see we have summarised the most common
classification along with the new harmonised classification).
Now the rules have changed for CBD and there is a harmonised
standard that brings the same classification to bear right across
Europe.
The key changes are as follows:
·Exclamation – Caution used in higher strengths
·Skull and Cross Bones – Danger used on 15.4mg or above
·The signal words and accompanying warning text has changed
All manufacturers need to make sure they are following this new
standard. The rule changed at the beginning of the year, and you had
until December 1, 2018 to get your products in the marketplace
to comply. That period of grace has now come to an end and any
product for sale needs to be in line with this standard, and that
includes products on shop shelves.
Just a few words on CLP. You need to have the symbol no smaller
than 1cm x 1cm and the accompanying text on your packaging,
the warning symbol has to be red on a white background.
You also need a tactile warning triangle on the packaging. This
should be on the body of the bottle and not just on the lid. And
finally, CLP needs to be on all layers of packaging.
When you calculate the percentage of nicotine, strictly speaking
it should be done by weight rather than volume, so a VG-heavy
18mg liquid might be below the cut off and still have exclamation
rather then skull and crossbones, that’s worth checking out.
Pods and CLP: The health and safety executive considers the pod
to be a layer of packaging so you need CLP on your pod at the
72 | VM20
point of sale. That is on the actual pod, not on the packaging that
the pod comes in. This can be accomplished with a removable
sticker, providing the sticker survives transit to the customer.
You also need to put the CLP in advertisements for your product,
this is especially important for online sales, the customer needs to
be informed on the safety of the product before they buy it. So, your
online listings need to have the full CLP clearly displayed.
Let’s look at some other aspects of labelling and packaging that you
should review. Use this checklist to conduct a quick audit on your
packaging:
·10ml bottles with certified child resistance re-closable – have you
validated the certificate from your bottle supplier?
·Nicotine strength maximum is 20mg/ml or 2 percent, don’t be
confused for nicotine salts. It’s the free-base nicotine we are
concerned with, not the weight of the salt.
·Each country should have their own language label and leaflet.
·Tactile triangle on the body of the bottle – near the bottom – no
other placing is permitted.
·The TPD warning, ‘This product contains nicotine and is a highly
addictive substance’ should cover 30 percent of the front and
back of the packaging. We go for a full wrap around on a bottle. If it
is sold as a bottle in a box, it needs to be on the box, but does not
need to be on the bottle.
·CLP and caution text needs to be up to date: It should say: ‘not to
be sold to people under 18.’
·The manufacturer / distributor should have their address, phone and
email on there.
·Ingredients in weight order should be listed with a description for
flavours, ie mint flavourings.
·There should be a batch number displayed to allow traceability
·It should have a best before date in UK date format: DD-MM-YYYY