Combined GHS + Consumer Labels

Regulations Involved

The requirements for workplace labels versus consumer labels varies depending on the jurisdiction. For some countries, a single label using Globally Harmonized System (GHS) labelling is sufficient for both workplace and consumer/retail labels, while in other places such as the EU, consumer labels are essentially workplace labels with some additional information. There are also certain countries whose workplace and consumer/retail labels are regulated under entirely different regulations that dictate what hazard symbols, hazard statements, and precautionary information must appear on the label. For example, workplace labels in Canada are regulated under the Hazardous Products Act and Regulations (also known as WHMIS), whereas consumer labels are regulated under the Consumer Chemicals and Containers Regulations, 2001 (CCCR), the Canadian Consumer Product Safety Act (CCPSA), and the Consumer Packaging and Labelling Act (CPLA) and its regulations.

There may also be certain federal or state/provincial regulations that dictate what kind of environmental and marketing claims are permitted to be used or require additional warnings specific to the product.

The goal of a chemical label is to effectively communicate the potential hazards of the chemical during handling, storage, or transport to the user. For workplace chemicals, the target audience is workers who will be exposed to the chemical for a long period of time but will have training and personal protective equipment to protect them, whereas the target audience for consumer chemical products will have a less reliable understanding of chemical hazards and equipment and must store the chemical product with consideration to children and pets.

In jurisdictions where there is a divergence in workplace versus consumer labelling, the intent of the modification was to tailor the label to include the most relevant and easily understood information for the intended audience. For example, a product that is only labelled for consumer use in Canada may omit information regarding chronic health hazards that is pertinent to workplace users, and a product that is only labelled for workplace use may fail to provide storage and handling instructions that are relevant for keeping young children safe as would be needed in a household setting.

Who Does This Apply To?

Chemical products that are intended to be used in workplaces and are also available to the general public must be labelled in such a way that they satisfy both the industrial workplace labelling requirements and the consumer product labelling requirements of the jurisdiction. This is often the case with construction and renovation materials that are available to contractors and DIYers at hardware stores, and for automotive fluids that can be purchased by both the professional and home mechanic.

Is This Regulation Mandatory?

In most countries, dual workplace+consumer/retail labels for hazardous substances and mixtures must inform users about product’s net quantity, hazards, handling and storage precautions, and first aid measures, if necessary. The specific requirements depend on the country, which may require additional information including but not limited to the country of origin, other markings or pictograms and/or information regarding the packaging.

What are the risks if a company chooses not to comply?

Improper storage and/or handling of a chemical caused by a non-compliant label could result in injury, illness, or death to the user. Consequently, a non-compliant label could incur significant fines and financial penalties for the chemical manufacturer or supplier and may also result in a product recall or stop sale order.

How Can Nexreg Ensure Your Compliance?

To determine if a label can be combined for workplace and consumer/retail uses, and to subsequently determine what label elements are needed, Nexreg can issue a GHS + Consumer Label Review Memo that outlines the required information in the jurisdiction’s official language(s). To complete this memo, we request that the following information be provided:

1. The full formula, to determine the product hazards;
2. Known physical data, to aid in hazard classification and determine if any exemptions or prohibitions apply
3. Container dimensions, to calculate the minimum required size of some label elements, and;
4. Current label artwork, if available.

For products that do not present many hazards and have a large enough label, it is usually a simple process to combine the workplace and consumer label elements. However, we recommend using separate labels for products with severe hazards since the space on the label is often too small for all the required label elements. In this instance, Nexreg can provide further guidance on how to label the product to ensure you are compliant.

Once the label artwork has been prepared according to the requirements in the GHS + Consumer Label Review Memo, Nexreg can review your draft label artwork to ensure it is in compliance.

For more information about our Label Review services click here.