A.I.S.E.’s contribution to European Commission Inception impact assessment regarding Simplification and digitalisation of labels on chemicals

Mid 2021, the European Commission organised a stakeholder consultation on the topic of Simplification of hazard information and use of e-labelling. Detergents being key to the scope of this work, A.I.S.E. contributed  with the following input on 10 Sept, building on its experience from the A.I.S.E. BRES project (Better Regulation & Safe Use) regarding CLP and Detergent Regulation implementation:

The European detergent industry, represented by A.I.S.E., strongly welcomes this initiative from the European Commission. We are committed to providing consumers and professional users with information to ensure the safe and sustainable use of products. For consumers, there is evidence, supported by a scientific publication, that current labels do not succeed at adequately conveying this.   A coordinated approach to provide product information via digital means would thus result in an improvement. For both consumer and professional products, duplication of information and inconsistencies due to different regulatory requirements must be tackled, in line with the Commission Better Regulation agenda. We call for labels to be "end-user relevant”. This means a label that provides the right information to ensure safe, efficient use of the product, considering the end user’s needs.

  1. The Detergents Regulation is a crucial regulation for our sector. However, since its implementation in 2004, new horizontal pieces of legislation have been adopted: REACH (2006), CLP (2008) and the Biocidal Products Regulation (2012). This has resulted in overlap including redundant labelling provisions for ingredients, allergenic fragrances and preservatives. The Impact Assessment provides an opportunity to eliminate discrepancies.
  2. Consumers rarely read labels. When they do, they spend very little time and can be confused by the information due to over-technical language and overcrowded content. One way to highlight information would be through use of icons or pictograms which, as evidenced by eye-tracking tests done in consumer studies, can draw a consumer’s attention more impactfully than text. The inclusion of A.I.S.E.’s "Keep away from children” safe use icon in the 8th revised edition of GHS (Annex 3) as an example of a precautionary pictogram confirms the value of visuals.
  3. Digital solutions can allow better information to users, especially consumers. The move to digital is now an established trend, driven by consumer preference and considerations/habits. Digitalisation of information can offer many benefits including improved readability, information in the reader’s language, increased font size for legibility, and increased access for certain groups. It can also help provide more context and further explanation to the on-pack info and additional resources. The information may also be customised according to the profile of the user.
  4. Embracing the potential of digital is also an important aspect for European future competitiveness, as enshrined in the Commission’s strategy for Europe’s digital future wherein the EU aims to become a global role model for the digital economy
  5. Industry has experience with online ingredient information: it is a Detergent Regulation requirement since 2005. Also, for energy labelling of household appliances, the relevant EU regulations require information online via URLs or QR codes, not on the energy label itself.
  6. Digital labels are being considered at global level. Several international organisations/governments have adopted policies to support the use of digital means for hazard information for chemicals. In the US, Smart-Label was implemented in 2015 by manufacturers of food and non-food products.

The UNSCEGHS is considering the opportunities that digitalisation may bring to convey GHS hazard information and general principles for implementation. 

A.I.S.E. is committed to working with all interested stakeholders to ensure that this transition is done in a smart, effective way, complemented by back-up solutions for users who require alternatives to digital information. A.I.S.E. looks forward to constructively contributing to this crucial study. Our full contribution and references are attached.