GHS (CLP/GHS system) IN PRACTICE - Agencija za hemikalije

Capacity of the packageDimensions(in millimeters)≤ 3 litres If possible, at least 52 × 74> 3 litres but ≤ 50 litres At least 74 × 105> 50 litres but ≤ 500 litres At least 105 × 148> 500 litres At least 148 × 2106.5 What about the size of the label elements?In general, CLP/GHS system requires that the label elements be of such size and spacing as to be easily read.The exact size of the letters of the signal words, hazard statements, precautionary statements and anysupplemental information is not further defined in the legal text, i.e. it is left to the discretion of the supplier. Thismeans that a stakeholder may decide himself whether he wants to increase the letter size with the overall volumeof the packaging and dimensions of the label, or to fix it more or less for all volumes and labels.Actually some stakeholders recommend to use a minimum letter size of 1,8 mm, in order to warrant the legibility ofthe text. However, this can be understood as recommendation only, but not as legal requirement which is fixed inthe CLP/GHS Rulebook.In relation to the hazard pictograms, CLP links the size of the pictograms to the minimum dimensions of thelabel: each hazard pictogram should cover at least one fifteenth of the surface area of the label dedicated to theinformation required by Article 17 of CLP/GHS Rulebook but the minimum area shall not be less than 1 cm 2 .However, where a supplier chooses to use a label that is larger than the minimum dimensions for a certaincapacity of the package, it is not necessary for the pictogram to be increased as well, provided it covers onefifteenth of the relevant minimum dimensions, i.e. for a container of a capacity > 50 litres, but ≤ 500 litres, theminimum size of a pictogram must be 32 mm x 32 mm, which is 1/15 of the minimum dimensions (105 mm x148mm) set out in Table 1.3 of Annex I to CLP/GHS Rulebook. Any additional area gained by increasing the sizeof the label can be used for further information which is considered important by the supplier.See also table under question 6.4!6.6 Are there any derogation from labelling requirements?Yes, there are. For substances and mixtures contained in packaging that is small (less than 125ml) or of suchform or shape that it is impossible to meet the requirements is otherwise difficult to label, CLP/GHS Rulebookprovides for exemptions from the regular labelling requirements. These exemptions allow the supplier to omit thehazard and/or precautionary statements or the pictograms from the label elements normally required underCLP/GHS Rulebook in case the substance or mixture is classified for the hazards listed in section 1.5 of Annex I toCLP/GHS Rulebook.CLP/GHS Rulebook sets out new rules for situations where packaging of hazardous substances or mixturesconsists of outer, inner and possibly also intermediate packaging.As a general rule, where the labelling of an outer packaging is in principle subject to both the transport and theCLP/GHS rules, the labelling or marking in accordance with transport legislation is sufficient, and the CLP/GHSlabelling need not appear. Similarly, where a hazard pictogram required by CLP/GHS relates to the same hazardas in the rules for the transport of dangerous goods, the hazard pictogram required by CLP/GHS need not appearon the outer packaging.31