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Topic: New CLP regulations  (Read 1935 times)
Alphya
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« on: June 03, 2015, 01:15:44 AM »

As some of us have found out recently, the new CLP (classification, labelling, packaging) regs are compulsory from 1st June 2015.
These regs apply to those of us who make candles/melts. CLP does not cover cosmetics, the Cosmetic Regs do.

It has been a massive shock to all of us, but I thought I'd share what we need to do. I've spent an incredible amount of time on this, from different suppliers/sources, and I have simplified it here for our labelling purposes:

There is a lady called Lynn who runs Silver Birch Fragrance who has written a guide.
Her FB group is https://www.facebook.com/groups/637754316326854
The guide is in the files. I'm going to translate it here though and make it very simple.

Her approach is similar to the way mine has been all along, but not all MSDS are in the same format with new hazard codes etc.

TWO key points really:

i) If a candle/melt contains more than a TOTAL of 1% sensitizing ingredients, it should bear the ‘exclamation point’ pictogram, the signal word 'WARNING', and the statement ‘May produce an allergic skin reaction’.

ii) If a candle/melt contains ANY INDIVIDUAL sensitizing ingredient at more than 0.1% in the final product (and that includes cosmetic allergens) the label should bear the statement: ‘Contains (sensitizer name). May produce an allergic reaction’;

- Sensitizers that we need to calculate have the 'Xi' or 'R' next to them in the chemical composition section (or whichever code corresponds from your section 2 hazards). The upper limit (if there is a range) must be assumed in order to work out the total % of those sensitizers in our products.
- Cosmetic allergens are also classed as sensitizers, because of the potential for skin contact, especially in the case of melts.


PART 1 TO WORKING OUT YOUR SENSITIZERS
In the case of cosmetic allergens, add up the total % of the cosmetic allergens in your product to get one figure which is the total allergen content in the pure FO. Then do your maths and work out (for example) the total allergen content for 5% FO, or whichever % you want to use. Keep that number handy, because you'll need it later.

PART 2 TO WORKING OUT YOUR SENSITIZERS
In the chemical composition part of the MSDS (usually section 3), see which ones correspond to your hazard/risk phrases from section 2, take the UPPER limit of those, and do the same calculation as with the cosmetic allergens, i.e, work out how much of that chemical will be in your chosen concentration of FO that you wish to use in your product.
Do the same for each sensitizer and apply the same rules as for cosmetic allergens.

IF any ONE/INDIVIDUAL sensitizer/allergen in your final product is over 0.1%, then you'll need to name that senzitizer in the form of:
'Contains (sensitizer name). May produce an allergic reaction'

IF you the TOTAL sensitizer/allergen content in your final product is over 1%, then you need to add the ‘exclamation point’ pictogram, the signal word 'WARNING', and the statement 'May produce an allergic skin reaction'.

Keep all your info written down/saved on your computer for each product you are producing, so that you can refer back.


I found out that old MSDS that don't have the new style pictograms/risk phrases on can still be used, as long as they have the chemical composition and cosmetic allergens. The regs talk of using 'translation tables' to do so.
Section 9 on this document shows that it is allowed:
http://echa.europa.eu/documents/10162/13562/clp_introductory_en.pdf

Regs are here: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008R1272-20131201
Go to Annex VII for the information.

FOR PICTOGRAMS - Search for 'annex iii' in the regs.
FOR THE CORRECT WORDING FOR HAZARD STATEMENTS - Search for 'annex iv' in the regs.
FOR THE CORRECT WORDING FOR PRECAUTIONARY STATEMENTS - Search for 'annex v' in the regs.


For products under 125ml, where all the information will not fit on a single label (on the candle/melt itself), the regs state that the info must be supplied as one of the following:

(a) in fold-out labels; or
(b) on tie-on tags; or
(c) on an outer packaging (if you have a candle in a box for example, the info does not have to go on the candle, it can go on the box)


* msds.jpg (104.67 KB, 752x480 - viewed 433 times.)
« Last Edit: June 03, 2015, 01:26:03 AM by Alphya » Logged

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« Reply #1 on: June 03, 2015, 05:47:57 AM »

Thank you Alphya.  Maybe we could add this to resourses?  It's a useful (and plain speak) guide.  What do you think?  :buttrf:
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« Reply #2 on: June 03, 2015, 07:11:47 AM »

Very useful, thank you.  :buttrf:
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Alphya
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« Reply #3 on: June 03, 2015, 08:24:35 AM »

Thank you Alphya.  Maybe we could add this to resourses?  It's a useful (and plain speak) guide.  What do you think?  :buttrf:

Sure thing Smiley
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« Reply #4 on: June 03, 2015, 09:21:37 AM »

Good grief...  I just noticed me typo there - I meant 'resources'  Roll Eyes

Thank you Alphya  :buttrf: :buttrf:  I will add it later.   Smiley
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« Reply #5 on: June 03, 2015, 09:50:55 AM »

absolutely bloody marvellous Alphya, thanks heaps.

May I just ask, what do the blue and red circles on the screen shot relate to please? Bit confused, and the blue circle is around a -

thanks Petal, you are a star, I can't ever get past the first paragraph of these types of docs, must be  from when I was a chemist and had to read  a lot of this stuff, now I can't bear to!
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Alphya
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« Reply #6 on: June 03, 2015, 10:34:27 AM »

The red shows the ingredients that correspond with the hazards, and blue shows no hazard x
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Suzanne
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« Reply #7 on: June 03, 2015, 12:11:02 PM »

Thank you!
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« Reply #8 on: June 03, 2015, 12:44:19 PM »

thankyou!  :buttrf:
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Suzanne
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« Reply #9 on: August 17, 2015, 07:28:41 PM »

Daft questions time......

I assume that I could just use an allergen calculator to work this out?

When do I add the dead fish and other pictograms?
« Last Edit: August 17, 2015, 07:40:32 PM by Suzanne » Logged

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« Reply #10 on: August 28, 2015, 01:09:37 PM »

Kelly, that's brilliant - thank you   :buttrf:

Like Suzanne I'm wondering if we can simply use the allergen calculator if we only add EO's and not FO's
I'm guessing our MSDS for EO's will have to tell us about the environmental hazards and so that'll let us know if we have to use the 'Dead Fish' symbol!

Is this the same ruling for Reed Diffusers - I'm guessing it probably is, but would like to be sure  Grin

At this stage we're keeping everything under 100ml, so labelling shouldn't be a big issue, but I'm curious as to how you're all dealing with that on larger candles etc - do you stick it on the bottom or does it have to be so you can read it without turning the burning candle upside-down
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Suzanne
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« Reply #11 on: August 28, 2015, 01:13:44 PM »

I think with Reed Diffusers you will also have the additional complication of the carrier liquid.
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