When is required child-resistant fastening (CFR) and/or tactile warning (TWD)?

The provisions described below apply for product packaging intended for the GENERAL PUBLIC, for example: products on sale/offer at a retailer’s or an outlet where the general public have open access to them, products sold to the general public through a website.

The requirements for child-resistant fastening (CRF) and tactile warnings (TWD) do not apply to product packaging which is for professional users only.

Table provides an overview of the hazard classifications triggering the CLP provisions for CRF and/or TWD.

IMPORTANT: CRF and TWD are not required if the substance or mixture is supplied in the form of an aerosol or in a container fitted with a sealed spray attachment and if the substance or mixture is not classified for another hazard triggering CRF or TWD.

Substances that directly trigger the CLP provisions for child-resistant fastenings and tactile warnings when they are contained in other substances or in mixtures at or above the denoted concentration :

- methanol, concentration limit 3%

- dichloromethane, concentration limit 1 %.


Child-resistant fastening (CRF)

A child-resistant package is a package consisting of a container and an appropriate closure which is difficult to open (or gain access to the contents) for young children under the age of fifty-two months, but which is not difficult for adults to use properly.

Annex II to CLP refers to two types of CRF for packages:

non-reclosable package - a package that, when all or part of the contents have been removed, cannot be properly closed again, for example a blister pack or air freshener refills; • reclosable package - a package (for example a one litre bottle or a five litre container) that, after it has been initially opened, can be reclosed and re-used numerous times without loss of security.

For fastening of the above-mentioned packages, Annex II to CLP requires conformity with the following standards, as amended:

• EN ISO 8317 (reclosable packages), and

• CEN EN 862 (non-reclosable packages).


Tactile warnings of danger (TWDs)

Packages provided with a TWD enables blind or visually impaired people to ascertain if the packages contains a hazardous substance or mixture.

A TWD must be placed on the packaging, so that it can be felt before accessing the contents. The warning must be located in such a way that any other embossed patterns do not cause confusion. The exact location of the TWD must be according to EN ISO standard 11683.

The TWD must also remain tactile during the expected period of use of the package under normal handling conditions. The TWD is not required on outer packaging such as for example a cardboard box protecting a glass bottle.

If you need any additional help, please don't hesitate to contact us (info@chem-consulting.si).


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