The other day I rolled up my sleeves and decided to spring clean the kitchen. Underneath the sink, between the cat food and rubber gloves, I have accumulated bottles and packets of all sorts of household cleaners, miracle grime busters, clothes and creams, all with enticing claims to make my cleaning tasks easier.
These contain a wide array of ingredients from soaps and perfumes to preservatives, bleach and acids, formulated to achieve their desired task, but posing a range of hazards to the consumer.
In my job in the Regulatory team at Rentokil, ensuring labelling of hazardous products complies with the appropriate legislation is an essential responsibility.
Labels play an important role in informing the consumer how to use a product and the safety information for hazardous ingredients it may contain.
When looking at the products under my sink I noticed all the labels looked different. So my regulatory brain wondered how effective they were at providing the information we need to use the products safely and effectively in the home.
There are numerous pieces of legislation that the product label must comply with before it can be placed on the market. This depends on the type of product, but in general terms, product labels have the following in common:
- product name;
- claims about the product capabilities;
- hazardous chemicals it contains;
- instructions for use;
- product manufacturer;
- graphics and logos; and
- storage conditions and disposal information.
Is the label the only way to provide information about how to use products safely?
With the rise of technology, there are various ways to communicate. So, is the label the most effective way to get important information to the user?
There are several ways:
- QR codes;
- “How to” videos;
- leaflets at point of purchase;
- telephone helplines.
All of these new methods would assume the user has access to suitable technology such as a compatible smartphone.
Perhaps the label will remain the key means for information exchange, at least for now because it is accessible to all. Keeping the label simple and easy to understand, eg using graphics, will help.
Safety legislation affecting household products
Here is a list of common household chemicals and some of the pieces of EU legislation they must comply with to ensure they do what they claim and are safe to use for both the consumer and the environment:
Washing powder and hard surface cleaners such as for tiles, kitchen worktops
Regulation (EC) No 648/2004 of the European Parliament and of the Council on Detergents.
Among other requirements, this regulation sets strict criteria for the biodegradability of the surfactants used in detergent formulations, to prevent pollution in rivers and waterways. It also stipulates the labelling requirements for detergent products. These require consumer products to list ingredients on the pack, including fragrances that are allergens.
Furniture polish and other handheld aerosols
Aerosol Dispensers Regulations (EU Commission Directive 2013/10/EU) sets out mandatory technical specifications to ensure the safety of aerosol dispensers. It also contains labelling provisions to inform consumers of the hazards presented by aerosol dispensers during use and storage.
Ant baits and insecticide powders
All pesticide formulations must comply with the Biocidal Products Regulation (EU) 528/2012, which is aimed at protecting humans and the environment from poisonous substances. This regulation stipulates that the product label must correctly and appropriately describe the product and give information on its safe use.
Shower gel, liquid soap and hand creams
In Europe, there are harmonised labelling requirements for cosmetic products under the Cosmetics Regulation (EC) No 1223/2009. Common label requirements include using identical terms for the product ingredients across Europe. These are known as the INCI list (International Nomenclature for Cosmetics Ingredients). Another important requirement is the inclusion of a date of minimum durability on the label, or Period After Opening (PAO) for products lasting more than 30 months.
The Paints Directive 2004/42/EC sets out maximum limits and labelling requirements for Volatile Organic Compounds “VOCs” thereby minimising environmental effects from their emissions and the toxic effects for the user who will be exposed to them while painting.
Air fresheners and plug-ins
There are several voluntary initiatives around the use of fragrances and air fresheners that go beyond the legal minimum. These cover not only the information on the product label but also standards around ingredients and safe levels for different fragrance types, levels of emissions, product shapes and advertising.
The voluntary initiatives are supported by Specialist Groups such as the International Fragrance Association (IFRA) and the International Association for Soaps, Detergents and Maintenance Products (AISE).
General supply regulations
As a general rule, all household chemicals must comply with the EU general supply regulations known as CLP. To give it its full name: European Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances, and it adopts the United Nations’ Globally Harmonised System on the classification and labelling of chemicals (GHS) across all European Union countries, including the UK.
CLP is the reason why we have seen the orange hazard symbols on labels change to the red and white diamond.
These numerous items of legislation covering thousands of products and ingredients go into great detail to ensure the safety of the consumer and the environment, but look extremely complex to the average consumer. The vast majority of consumers, however, will only have a label to inform them about the product they are buying.
Manufacturers sell their products in countless different shapes and sizes of container, each with a customised label size and shape for displaying the product information. The legislation ensures that all the products provide adequate information on the label, displayed in a readable format. The result is that the consumer is assured they are buying what they expect and are provided with information how to use the product safely and about any hazards involved.
So, read the label.