A question that many companies often ask when drawing up labels for hazardous chemicals is “Does the CLP Regulation specify a minimum font size for labels?” In this article, we address the legal obligations and other guidance available to help suppliers ensure their labels are readable and meet minimum requirements.
Minimum legal requirements
Unlike the overall label size and pictogram size, wherein there are specific size requirements included in the regulation, CLP does not include any minimum sizes for the other label elements, such as Product Names, Signal Words and Hazard and Precautionary Statements. Instead, it contains a much more subjective requirement that these label elements “stand out clearly from the background and be of such size and spacing as to be easily read” (CLP Article 31(3)). This requirement that the label be “easily read” has been deliberately included in this form in recognition of the fact that the readability of text on the label is not just a function of text size, but is also influenced by many other factors, including typeface, text and background colour, space between lines, between words and between the letters of each word, stroke width, print quality, paper quality and so on.
Nevertheless, this is an area where companies continue to seek guidance. To address this need for additional guidance, together with a number of other labelling issues, an update to the ECHA Guidance on Labelling and Packaging is currently under development. The draft updated guidance document, and information on its progress and how to provide feedback, can be found at the ECHA website. The draft update includes expanded advice to help companies understand the effects of some of these different factors on the readability of text, and also includes a new recommendation for a minimum letter size of 1.2mm (x-height). This does not mean the total height of the text should be 1.2mm, but that the height of the letter x in a word should be 1.2mm. If one assumes that the letter x is approximately half the height of taller letters, this would give an overall size of text height of 2.4–2.5mm, or approximately 7 point. This recommendation is in line with other EU legislation where minimum text sizes are mandatory, eg EU Regulation 1169/2011 on food information provision to consumers.
Figure 1 Explanation of x-height taken from EU Regulation 1169/2011, Annex IV
The draft guidance also suggests that suppliers may decide whether to increase the letter size with the overall volume of the packaging and dimensions of the label, or to fix it more or less for all volumes and labels. In making this decision, suppliers may want to consider how different size containers and packages may be handled, and at what distance it is reasonable to expect that someone should be able to read the label and under what conditions. Would you expect someone to be able to read the same text size on a label on a large drum outside in the rain, as a small bottle indoors with good lighting?
Of course the CLP guidance is just that. It is not part of the legal text of CLP and on its own has no legal standing. If in doubt as to whether your labels can be easily read, you may want to assemble a panel of several of your colleagues, especially those that wear spectacles or have other eyesight problems, and ask them to look at the label from the distance they would normally look at the package when using it. If they can all easily read the label, it is likely that a court or jury would also judge it to be readable. If on the other hand, one of your colleagues needs to hold the container a foot from his or her face to read it, the text is probably too small, especially if the product inside is corrosive or causes severe eye damage! On small containers with limited label space, increasing the text size and, therefore, space requirements on the label can involve some tricky negotiations with marketing colleagues. Regulators (or courts in the worst case) will not, however, see company logos and other marketing information as an essential or important label element, no matter what that company’s corporate design guide might say.
Of course CLP applies only in the EU, and other jurisdictions that have implemented the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) have developed their own sets of recommendations and requirements. The Australian Code of Practice for the Labelling of Workplace Hazardous Chemicals includes a sliding scale for both pictogram and text size depending on container size. This scale starts with a minimum text size of 2.5mm (approximately 7 point) for containers with a capacity of 500ml or less to a minimum text size of 7mm (approximately 20 point) for containers with a capacity of 25 litres or more.
Figure 2 Australian Code of Practice on Labelling of Workplace Hazardous Chemicals guide for the minimum dimensions for hazard pictograms
Eagle-eyed readers (pun not intended) may also have identified that the recommended minimum pictogram sizes for containers are significantly larger in the Australian Code of Practice than the minimum sizes recommended under CLP.
Malaysia’s chemical labelling regulations also include a requirement for label text to have a minimum text size of 7 point. Other jurisdictions have adopted the more general recommendations from the GHS that pictogram and text sizes should increase proportionally with each other.
In addition to legal requirements on minimum text sizes useful guidance on appropriate text sizes for labels may be found in documents such as the American standard ANSI Z535.4 — Product Safety Signs and Labels which includes a chart (Table B1) comparing safe reading distances with minimum and recommended letter heights for favourable and unfavourable reading conditions. This document considers a letter height of 2.5mm to be the minimum for reading from a distance of 2 feet (60cm) under favourable reading conditions, but recommends a letter height of just over 4mm (approximately 11 point) for favourable reading conditions and 4.26mm (12 point) for unfavourable reading conditions.
Many companies use dedicated software packages to produce their labels and these can sometimes impose limitations on the size of text that can be included on a label, or be difficult to scale for small labels while still ensuring readability. If looking for a new software package, the recommendations in this article may provide useful information to consider when comparing different systems.
Deciding on suitable text size for labels for hazardous chemicals is left to the discretion of suppliers. A minimum text size of 2.5mm (x-height 1.2mm) or 7 point is the smallest size that most people (and regulators) are likely to consider readable. Where space permits text size should be increased proportionally with label and container size to ensure good readability. At the end of the day, readability is a subjective judgment, and perhaps the most important question to ask yourself is “Would you be happy to receive this label?”
Last reviewed 4 July 2016