Digital Labelling Requirements: CLP Compliance & QR Code Implementation
CLP Regulation Article 34b. & Annex I. Section 1.6.
The revised CLP Regulation introduces provisions for digital labelling of chemical products. These provisions will become applicable on January 1, 2027. From this date, companies have the option to provide certain labelling information in a digital format, supplementing the traditional physical labels.
For products already on the market before January 1, 2027, there is no obligation to re-label or re-package them to meet the new digital labelling requirements. These products can continue to be supplied without changes until January 1, 2029.
1. General Principles of Digital Labelling
- Label elements must first be provided on a physical label.
- In addition to the physical label, a digital label may also be provided.
- Some specific label elements (as defined in Annex I, Section 1.6) may be provided exclusively in digital format.
- If digital labels are unavailable at the time of purchase or upon request, suppliers must provide the information by alternative means, free of charge.
2. Technical Requirements for Digital Labels (Article 34b)
- Unified Information: All required label elements must be available in one place and separate from other information.
- Searchable Content: Users must be able to easily find specific hazard and precautionary information.
- Long-Term Accessibility: Digital labels must be available for at least 10 years after the product is placed on the market.
- No User Barriers: The information must be accessible without registration, passwords, or the need to install an application.
- Accessibility Standards: Must be readable for vulnerable groups (e.g., visually impaired users).
- Quick Access: The necessary safety information must be accessible within two clicks.
- Cross-Platform Compatibility: Digital labels must be usable on all major operating systems and web browsers.
- Unrestricted Language Access: If provided in multiple languages, language selection must not be restricted by geographical location.
3. Data Carrier and QR Code Implementation
- If a QR code or barcode is used to provide a digital label, it must be firmly affixed to the physical label or packaging.
- The label must include a statement such as “More hazard information available online” to direct users to the digital label.
4. Privacy and Data Protection
- It is strictly prohibited to track, analyze, or use user data collected from digital labels for any purpose beyond hazard communication.
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