The requirements for labeling, advertising and distance selling as well as the implementation period for reclassification by the upstream supplier or raw material manufacturer are of particular importance for the paint, varnish and printing ink industry. On various occasions, companies, the VdL and CEPE have expressed concerns about the practicality of the new revision.
New hazard classes
New hazard classes were already introduced in 2023 via a Delegated Ordinance. In a second step, the text of the regulation was amended and published in the Official Journal of the European Union in November 2024. The implementation of the regulatory requirements affects almost all products in the industry - especially the new requirements for the design of labels. The Commission's focus here was on improving legibility.
Label specifications hardly feasible
The minimum font sizes for labels have been redefined. The regulations for advertising have also been adapted. Numerous manufacturers are forced to fundamentally revise existing container sizes, label formats and storage processes. Small-volume packaging, for which the required label specifications can hardly be physically implemented, is particularly affected. The consequence: a reduction in the variety of the product range, as many products become unprofitable from an economic point of view. In many cases, member companies have to switch to folded labels, but this involves extensive technical adjustments.
Significant financial burden
The economic impact of the new regulations on companies is considerable. The conversion costs range from several hundred thousand to several million euros - depending on company size, product range and existing infrastructure. The implementation is also associated with considerable personnel costs. Many companies have had to create new jobs or reallocate existing resources.
Alternative solutions
As a viable alternative to physical multi-layer labels, some feedback companies suggest the use of digital solutions. QR codes could provide information efficiently and in multiple languages - a model that is already established in the pharmaceutical industry. The massive effort involved in reporting to poison information centers was also discussed. Companies complain that the effort involved - both financially and technically - is disproportionate to the benefits, especially in the case of small quantities or special batches. The demand for a standardized, preferably digitalized and leaner solution across Europe is therefore shared across all sectors.
Prospects and next steps
In the wake of the EU Commission's announcements on reducing bureaucracy, simplification and greater competitiveness, VdL and CEPE, together with many allied associations, are trying to bring about a short-term amendment to the CLP Regulation.
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