With Trading Standards becoming increasingly concerned with products that don’t follow CLP Regulations, we’ve created a short guide to help you understand them. In this article, we cover what CLP is, what it means for the pet care industry and what happens when products aren’t compliant. As experts in CLP compliance and product reformulations, we’ve also covered how to find out if your products are compliant and how to bring them in line if they aren’t.
What is CLP Regulation?
CLP stands for ‘The Classification, Labelling and Packaging of Chemicals Regulation (EC) No 1272/2008’. It is based on the United Nation’s Globally Harmonised System (GHS). CLP is most commonly known for regulating household products, such as washing up liquid. Pet care products in the UK also fall under this regulation, NOT the Cosmetic Product Directive, despite many products incorrectly following the latter.
CLP was introduced in the UK in 2009, and the cut off for bringing products in line with the regulation was June 2017. After this date, all products which fail to comply are at risk of legal action.
What are the rules?
CLP is triggered when something hazardous is contained within a product. Each hazard has a maximum % allowed before a warning symbol, hazard or precautionary statement MUST be displayed on the product’s packaging. The two most common causes of triggers in pet care products are surfactants (soaps) and fragrances.
Below are the warning/danger symbols that may be required if CLP is triggered:
If a product triggers a hazard, the symbols MUST be displayed in the correct format (above) and sized 1cm² on any product under 3 litres. It must also be outlined in red on a white background with a black symbol. This ensures the symbols are visible and cannot be ‘hidden’ on a product’s label.
As well as pictograms, products may also be required to include warning text on their labels when a hazard is triggered, such as “may cause an allergic reaction”.
What happens if a product isn’t CLP compliant?
Trading Standards are responsible for monitoring whether products in the UK comply with CLP Regulations. Failure to comply can result in a large fine and a full product recall.
When it comes to making changes to bring products in line, it goes without saying that a warning/danger symbol on the product’s packaging would be off-putting for customers. Instead, brands usually choose to reformulate their existing product to reduce or remove certain ingredients to avoid a trigger.
Other important pet care regulations
All preservatives used in a pet care formulation that’s sold in the UK MUST be listed on article 95 of the Biocidal Products Directive under the correct product type and MUST have been supplied by a registered licence holder and/or approved downstream supplier.
Unlike personal care products that fall under the Cosmetic Product Directive, pet care products DON’T require an INCI (ingredients) list. They DO, however, need to list certain ingredients and their inclusion levels in the ‘contains’ section of the product.
Here’s an example of a fully compliant pet care product’s label made by Group55 for our own brand, Animology.
How to check if products are CLP compliant
At Group55, we’re experienced in running compliance checks and reformulating pet care products to bring them in line with CLP and all pet care regulations.
If you would like to check whether your pet brand’s products are in line with regulations or discuss a reformulation project, we’re here to help. Get in touch with us and we’ll guide you through the process.