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Can I Combine my USA, Canada, and European Labels Into One?

Can I Combine my USA, Canada, and European Labels Into One?

In a recent consultation, a customer was launching several products in North America and the European Union. Needing help with their label, they approached ICC to assist.

“I would like to have ONE label for the United States, Canada, and the European Union. It will make our logistic process so much easier.” It sounds like a great idea, but it is doable?

The answer is PERHAPS.

To answer the question, we need to understand the criteria from the OSHA Hazcom, WHMIS, and EU CLP regulations.

According to both OSHA Hazcom and WHMIS, the label must consist of Pictograms, Signal word, Hazard statements, and ALL precautionary statements. The key word in that sentence is “ALL” The OSHA regulations state (1900.1200, Appendix C2.4.1) There are four types of precautionary statements presented, “prevention,” “response,” “storage,” and “disposal.” The core part of the precautionary statement is presented in bold print. This is the text, except as otherwise specified, that shall appear on the label. The Canadian WHMIS says the equivalent.

In the EU, Article 28 Principles of precedence for Precautionary Statements (3) states,” Not more than six precautionary statements shall appear on the label, unless necessary to reflect the nature and the severity of the hazards.” Further Label Guidance Version 4.2 March 2021

The CLP Regulation requires that normally not more than six precautionary statements must appear on the label, unless necessary to reflect the nature and the severity of the hazards. Therefore, a substantial reduction of the number of precautionary statements must be performed based on effective selection rules.

Since the criteria are different, having one label proves difficult in most situations. In a case where the classification is simple, like Eye Irritation, it would be possible since there are less than six precautionary phrases.

Wash thoroughly after handling. Wear eye protection/face protection. If in eyes: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If eye irritation persists: Get medical advice/attention.

But, if you had a Flammable liquid classification, it would not work since there are more than six precautionary phrases.

Keep away from heat, hot surfaces, sparks, open flames and other ignition sources – No smoking. Keep container tightly closed. Ground and bond container and receiving equipment. Use explosion-proof electrical and ventilating equipment. Use only non-sparking tools. Take precautionary measures against static discharge. Wear protective gloves and eye/face protection.

IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water/shower. In case of fire: Use water fog, dry chemical, CO2 or ‘alcohol’ foam to extinguish. Store in a well-ventilated place. Keep cool. Store locked up. Dispose of contents/container in accordance with local/regional/national/international regulations.

ICC Compliance Center has a team of full-time Regulatory Experts who have years of experience and are certified/recognized in their field of expertise. Contact us if you need help with compliant labeling, and we will work with you to find a compliant solution. Ask us your tough questions by calling 888.442.9628 (USA) or 888.977.4834 (Canada).

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Karrie Ishmael, CDGP

Karrie Ishmael has been with ICC since 1988. She has contributed to ICC's growth in various capacities, including customer service, sales, and marketing. In her current role as ICC's Senior Regulatory Expert and SDS author, Karrie conducts hazardous materials training classes in 49 CFR, IATA, IMDG, TDG along with OSHA and WHMIS hazard communication courses. When not training, she writes safety data sheets for customers to comply with North American and European requirements. She actively participates in many associations, including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.