E-Cigarette-Vaping-CLP

The public, and even the industry, has been bewildered by the variety of warning signs on bottles of ‘e-liquid’. Some brands look like you shouldn’t open them without wearing a hazmat suit, whilst others have bottles that appear as innocent, refreshing elixirs. But which is right? Which is wrong? And why have even respected authorities frequently changed their stance on what is required, despite no changes in legislation since June 2014?

You can download our comprehensive paper on correct CLP classification here: CLP-classification-of-e-liquid-by-Xyfil-ltd

Working closely with our distribution network, My Vapery, we wanted to help clear the confusion once and for all.

“On the whole, vendors and manufacturers want to do the right thing. The problem has been utter confusion as to what the right thing is” says Steven Lauder, manager of My Vapery. “Some retailers don’t want to sell liquids without tactile warning triangles and hazard symbols. Others won’t sell liquids that have them, as they don’t want the product to appear more dangerous than it might be. This has made life very difficult for manufacturers and retailers, let alone consumers.”

Classification and labeling of potentially toxic products is covered by CLP regulation. The regulation covers a variety of chemicals – from household to industrial products – based on complex calculations of toxicity. E-Liquid (or eJuice) consists primarily of Propylene Glycol, Vegetable Glycerine, Nicotine and natural or artificial flavourings. Much research has been done on all of these substances, with flavourings being the main ‘unknown’, in terms of their suitability for inhalation, despite being safe for oral consumption.

“I didn’t understand why it had been so difficult to determine the correct CLP classification and related labeling information for e-liquids. I was quite surprised to learn that some of the trading standards agencies had released statements that advised manufacturers to include the same hazard pictograms and statements that you would use on pure nicotine”, says Dr Dilip A. Bhuva, PhD, Chief Science Officer at Xyfil Ltd.

“All of the major constituents of the e-liquid have been well researched in terms of their toxicity. It was just a case of pooling the data from existing literature into a cohesive document and undertaking the necessary calculations for classification. Based on these calculations, eLiquid was then classified in various categories – physical, human toxicity, aquatic toxicity, etc. – and relevant labeling information can then be determined.”

The document has been looked at by the CLP helpdesk and although they cannot endorse CLP classification by any organisation, they have agreed with the approach to classification that was presented. They have noted, among various other things, that “[Dr Bhuva] appears to have a good understanding of the requirements of the CLP Regulation and their application to e‐cigarettes/liquids.”

Please download our CLP Classification and Labeling Requirements for Nicotine-containing E-Liquids paper for the comprehensive answers to all of your CLP concerns.

If you would like any further information on the above article or any help related to TPD compliance please email compliance@xyfil.com or call 01772 888 778

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