Epy

IF DANGEROUS GOODS ARE PACKAGED IN DIFFERENT PACKAGING, THE DANGER LABEL MUST BE SHOWN ON THE INTERIOR PACKAGING, ON THE OUTER PACKAGING OR ON BOTH?

In case of combination packaging containing goods which are classified and labelled in accordance with the rules on the transport of dangerous goods (ADR,ADN, RID, IATA, IMDG Code), but require a CLP labelling, the CLP hazards labels are mandatory on each internal and intermediate packaging, and optional on the outer packaging. This applies also in case of simple marking (for example: LQ exemption mark). Any hazard labels (or mark) for transport will have to be shown on outer packaging. If the product is not classified and labelled in accordance with the rules on the transport of dangerous goods, then the CLP label is required on both the inner packaging, than on the intermediate and externally.

IN WHICH CASES, WHEN PACKAGING CONTAINS DANGEROUS SUBSTANCES OR PREPARATIONS SOLD IN RETAIL SHOULD THERE BE INDICATED A TACTILE INDICATION FOR THE BLIND AND A SAFETY CLOSURE FOR CHILDREN?

Depending on the regulation of art.8, clause 3 of the Legislation Decree n.65 of the 14/03/2003 and the art.19, clause 1 of the Legislation Decree n.52 of the 3/02/1997, and to the awareness of Regulation (CE) 1272/2008, Attachment II, Part 3,the tactile indication for the blind must be represented on the packaging of any capacity containing a dangerous substance or preparation sold in retail, if classified as presenting dangers of severe toxicity, corrosion to the skin, MUTAGENICITY on the germ cells (category 2), damage to the respiratory system or STOT, (category 1 and 2), as dangerous in case of aspiration o as gas, liquids, or flammable solids (category 1 and 2).
The disposal doesn’t apply in the case of aerosols classified and labeled as “ extremely flammable aerosols” or “flammable aerosols”.
Whereas the safety closure for children must be present:

  • On the packaging of any capacity containing a dangerous substance or preparation sold in retail and classified for the severe toxicity )category from 1 to 3), STOT – singular exposure (category 1), STOT – repeated exposure (category 1) or skin corrosion ( category 1);
  • On the packaging of any capacity containing a substance or mixture supplied to the public that can represent a danger in case of aspiration ( Xn, R65 and H334, Asp.Tox.1) except from the preparations placed on the market under the format of aerosol or in a container equipped with a sealed spraying device;
  • On the packaging of any capacity sold in retail, in which there is at least one of these two substances present: Methanol (CAS 67-56-1; CE 200-659-6) in concentrations above or equal to 3% or/ and Dichloromethane (CAS 75-09-2; CE 200-838-9) in concentrations above or equal to 1 %.

To be excluded from this limitation, it is necessary that the end use of the dangerous substances or preparations may only be for a professional nature.
In this case, it is necessary to cite the lettering “ for Professional use only” on the label.