The CLP regulations provide a safety net for the sale of potentially hazardous consumer products. By ensuring that such products are supplied in child-resistant packaging, and bear the appropriate hazard and precautionary statements, public safety may be assured. Classification under CLP is the responsibility of the supplier. Data for nicotine (as a pure substance) is part of the harmonised classification data contained within the CLP regulation and this data formed the basis for the classification of nicotine containing mixtures.

Ecig Juice Regulations: CLP’S Call. Since the other main constituents (propylene glycol and glycerol) are not acutely toxic, the classification of e-liquid is dependent on the level of nicotine they contain. The CLP Regulation (for "Classification, Labelling and Packaging") is a European Union regulation from 2008, which aligns the European Union system of classification, labelling and packaging of chemical substances and mixtures to the Globally Harmonised System (GHS).

What the law requires

Arguably, the recommendations contained in BSI PAS 54115 and in this ISE are legal requirements under the General Products Safety Regulations (2005), which stipulate:

Part 2, Section 6:

(3) In circumstances other than those referred to in paragraphs (1) and (2), the conformity of a product to the general safety requirement shall be assessed taking into account—

(a) any voluntary national standard of the United Kingdom giving effect to a European standard, other than one referred to in paragraph (2),

(b) other national standards drawn up in the United Kingdom,

(c) recommendations of the European Commission setting guidelines on product safety assessment,

(d) product safety codes of good practice in the sector concerned,

(e) the state of the art and technology, and

(f) reasonable consumer expectations concerning safety.

Therefore, as in BSI PAS 54115, the labelling recommendations below should be recognised as requirements under the General Product Safety Regulations (2005).

Ecig Juice Regulations: CLP’S Call. Nicotine solutions of less than 2.5% are not classified under CLP. (Please note: This is currently under review, and may change in the future. If such a change is introduced, this advice may no longer be applicable.) E-liquids may be sold separately from hardware, i.e. in bottles, or may be supplied prefilled into various devices. Some of the devices may be sold with the intention that they will not be refilled, while others will be intended for refilling using e-liquid in bottles. This introduces a slightly different set of labelling requirements, depending on the product in question, as set out below:

Irrespective of how the e-liquid is sold, if it has a nicotine concentration of between 0 and 2.49%, it should carry the following information:

•  the heading: “CAUTION:”
•  the text: “Keep out of the reach of children and pets”
•  the text: “Only for use in/with [delete as appropriate] electronic cigarettes*”
•  the text: “Seek medical advice if you feel unwell”
•  the text: “May contain traces of [allergen]” (see section 4 below)
•  Nicotine concentration in weight per volume (w/v) percentage and/or milligrams per millilitre (mg/ml) must be displayed on the label
•  the batch number must be displayed
•  the ‘Best Before End’ date must be displayed
•  contact details must be displayed
•  For e-liquids supplied in bottles for refilling various devices, the labelling should include the following additional elements:
•  the text: “* Refer to device manufacturer’s instructions for refilling”
•  the nominal quantity of the solution contained in the bottle must be displayed
•  For prefilled products, where the e-liquid is supplied with the hardware as a composite product (and where it is not intended for refilling), the labelling should state (in addition to the requirements above):
•  the text: “* This device is not intended for refilling”
•  the number of prefilled cartridges/cartomisers in the pack (including if there is only one) must be displayed
•  For prefilled products, where the e-liquid is supplied with the hardware as a composite product, but which is intended for refilling using bottled e-liquids, the labelling should state (in addition to the requirements above):
•  Either the text: “* Refer to device manufacturer’s instructions for refilling” or “*Refer to refilling instructions enclosed” (if you are providing them with your hardware). (Please note that if you are placing a product on the market which is intended for
• refilling, you should be providing instructions on how this is done for your specific product, to ensure that even naïve consumers can find out how to refill their device safely.)

Ecig Juice Regulations: CLP’S Call. All of these label elements must be visible, legible and indelible. Concentrations in this range should also be supplied in child-resistant enclosures. There are about another situation of the e-juice such as CLP’s requirements for e-liquids containing 2.5% and over

Please note: It is important that zero nicotine e-liquids also bear this information.

tags:Ecig Juice, ejuice