In certain specific cases the packaging of a product can be so unique that it is difficult to meet the CLP labelling requirements.
The figure below shows an example of a popular two-component adhesive sold as a kit consisting of two mixtures, namely an epoxy resin (Part A) and a hardener (Part B).
The two mixtures are placed in separate containers which are fixed together and sold as a kit in transparent outer packaging. When used, the content of both containers is mixed after or during extrusion. Part A and Part B react to produce a final mixture, which can be used as an adhesive for a wide range of materials.
In this type of situation, two separate labels need to be affixed to the containers (one label for each mixture (in a container)).
The hazard information provided on the labels must relate to the form/physical states in which both mixtures (Part A and Part B) are placed on the market.
On each label the UFI relevant for the specific mixture has to be included. The outer packaging of the whole kit need not be labelled, as it is transparent and permits the inner packaging (both containers) to be clearly seen.
If the product formed during end-use is hazardous (with different properties to the mixtures in the containers), sufficient instructions to enable safe use must be provided to the user. The instructions can for example be provided on the label or as a separate leaflet in the package.
If such a product is not intended for the general public, two separate SDSs should be provided to enable the users to meet their responsibilities in relation to the management of risks arising from the use of the reaction product that occur upon the end use of the two mixtures (i.e. the adhesive).
As the adhesive in the example is also classified as hazardous, the relevant information about the risk management measures should be provided in the SDSs.
Please note that the examples only illustrate the general aspects of labelling of two-component products and are not intended to present the correct selection of appropriate label elements.
A case-by-case judgement may be necessary when determining the labelling requirements for similar, unique packaging. The information should not confuse the user and the label should be easily understandable.
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SOURCE: ECHA
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