REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL ON COMMUNICATION ON THE SAFE USE OF CHEMICALS
Date: 2012-10-29
Institutions: European Commission
Subjects: chemical product, consumer information, dangerous substance, labelling, marketing standard, safety standard

EUROPEAN 
COMMISSION 

Brussels, 29.10.2012  
COM(2012) 630 final 

REPORT FROM THE COMMISSION 

TO THE EUROPEAN PARLIAMENT AND THE COUNCIL ON COMMUNICATION 
ON THE SAFE USE OF CHEMICALS 

(Text with EEA relevance) 

EN 

   EN 

 
 
 
 
  
 
REPORT FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT AND THE COUNCIL  
ON COMMUNICATION ON THE SAFE USE OF CHEMICALS 

(Text with EEA relevance) 

Glossary 

ECHA    
CLP  

GHS  
REACH  

RCN    
MSCA  
SDS  

European Chemicals Agency 
Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of 
Substances and Mixtures 
Globally Harmonised System of Classification and Labelling of Chemicals 
Regulation  (EC)  No  1907/2006  concerning  the  Registration,  Evaluation, 
Authorisation and Restriction of Chemicals 
Risk Communication Network 
Member States Competent Authority 
Safety data Sheet 

1. Introduction 

The  European  Union  has  developed  systems  for  providing  information  on  hazardous 
properties and control measures of chemicals since 19671 for substances, and since 19882 for 
mixtures  (earlier  referred  to  as  'preparations').  Yet,  the  classification  systems  used  in  other 
countries  were  different  and  not  always  compatible  with  each  other,  which  often  required 
multiple labels and Safety Data Sheets for the same chemical product.  

Therefore, the 1992 United Nations Conference on Environment and Development provided 
an international mandate to harmonise hazard classification by the year 2000. As a result, the 
first version of the Globally Harmonised System of Classification and Labelling of Chemicals 
(GHS) was approved in 2002 and then published the following year. Since then, the GHS has 
been  updated  every  two  years.  GHS  is  a  United  Nations  system  to  identify  the  hazards  of 
chemicals and to inform users about these hazards through standard symbols (pictograms) and 
phrases on the packaging labels and through safety data sheets (SDS).   

1 
Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and 
administrative provisions relating to the classification, packaging and labelling of dangerous substances, OJ 196, 
16.8.1967, p. 1–98. 
2 
administrative provisions of the Member States relating to the classification, packaging and labelling of 
dangerous preparations, OJ L 187, 16.7.1988, p. 14–30. 

Council Directive 88/379/EEC of 7 June 1988 on the approximation of the laws, regulations and 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
CLP is the EU Regulation on Classification, Labelling and Packaging of chemicals substances 
and mixtures3. It aligns previous EU legislation on classification, labelling and packaging of 
chemicals to the GHS. The CLP Regulation aims to enhance the protection of human health 
and the environment, while ensuring free movement of chemical substances and mixtures, and 
enhancing competitiveness and innovation.  

The CLP Regulation entered into force on 20 January 2009. According to the Regulation, the 
deadline  for  aligning  substance  classification  to  the  new  rules  was  1  December  2010.  For 
mixtures, the deadline will be 1 June 2015. The CLP Regulation will ultimately replace the 
previous  rules  on  classification, 
labelling  and  packaging  of  substances  (Directive 
67/548/EEC) and current rules on preparations (Directive 1999/45/EC) after this transitional 
period.  

Article 34 of the CLP Regulation lays down that:  

1.  By 20 January 2012 the Agency shall carry out a study on the communication 
of  information  to  the  general  public  on  the  safe  use  of  substances  and 
mixtures  and  the  potential  need  for  additional  information  on  labels.  This 
study  shall  be  carried  out  in  consultation  with  competent  authorities  and 
stakeholders and drawing as appropriate on relevant best practice. 

2.  Without  prejudice  to  the  labelling  rules  provided  for  in  this  Title,  the 
Commission shall, on the basis of the study referred to in paragraph 1, submit 
a report to the European Parliament and the Council and, if justified, present 
a legislative proposal to amend this Regulation. 

The  European  Chemicals  Agency  (ECHA)  has  assessed  the  findings  of  a  Europe-wide 
Eurobarometer  survey  and  of  a  further,  more  targeted  study  on  risk  perception.  As  a  result, 
ECHA  has  published  its  study  in  accordance  with  Article  34  (1)  CLP  on  20  January  2012. 
This Report has been established on the basis of the study conducted by ECHA in accordance 
with Article 34 (2) CLP.  

2. Study on the communication of information on chemicals to general public  

The CLP Regulation incorporates the classification criteria and labelling rules agreed at UN 
level  into  EU  legislation.  The  basic  principles  are  actually  rather  close  to  the  previous  EU 
legislation.  The  Regulation  requires  companies  to  classify,  label  and  package  appropriately 
their hazardous chemicals before placing them on the market.  
According  to  the  CLP  Regulation,  communication  of  hazards4  of  chemicals  in  the  form  of 
labelling  is  the  main  way  to  inform  the  general  public  on  the  safe  use  of  chemicals.    In 
particular, the CLP hazard label encompasses the following elements: 

(a)  

the hazard pictogram (as specified in Annex V to the CLP Regulation), intended as a 
graphical composition that includes a symbol plus other graphic element in order to 
convey specific information on the hazard concerned; 

Regulation (EC) No 1272/2008 of the European Parliament and the Council on classification, labelling 

3 
and packaging of substances and mixtures, OJ L 353, 31.12.2008, p. 1. 
4 
effects on human health or the environment as established in accordance with the criteria of the CLP Regulation. 

The term hazard refers to the intrinsic capacity of chemical substances or mixtures to cause adverse 

3

 
 
 
 
 
 
                                                 
(b)  

(c)  

the  signal  word  that  indicates  the  relative  level  of  severity  of  hazards  to  alert  the 
reader to a potential hazard (i.e. Warning, Danger);  

the  precautionary  statement  that  describes  recommended  measures  to  minimise  or 
prevent adverse effects resulting from exposure to a hazardous substance or mixture 
due to its use or disposal (precautionary statements are standardized and are defined 
in Annex IV of the CLP Regulation); 

(d)  

the hazard statement that defines the nature of the hazards of a  hazardous substance 
or mixture, including, where appropriate, the degree of hazard (hazard statements are 
standardized and are defined in Annex IV of the CLP Regulation) 

In  accordance  with  Article  34(1)  of  the  CLP  Regulation,  ECHA  carried  out  a  study  to 
evaluate the communication on information to the general public on the safe use of substances 
and  mixtures  and  the  potential  need  for  additional  information  on  the  label.  The  study  was 
based on two main elements: 

a)   a  Eurobarometer  opinion  poll  conducted  in  2010,  which  surveyed  the  perceptions  of 
European citizens towards the label comprehension and understanding of related  hazard 
pictograms.  The  survey  involved  more  than  26  000  members  of  the  public  from  all 
Members States and the results published in 2011 were considered as representative of the 
views of 500 million citizens in the EU.   

b)   an additional qualitative study conducted in 2011 - by a team of European academics with 
expertise in risk perception, research and analysis - in order to provide further elements 
on  public  perceptions  and  individual  behavioural  patterns.  The  study  consisted  of 
interviews  with  over  240  citizens  in  three  Member  States  and  intended  to  reveal  how 
people  evaluate  chemical  products  and  how  these  judgements  link  to  safety-relevant 
behaviours. 

On 20 January 2012, ECHA has transmitted the report on the "Study on the Communication 
on  Safe  Use  of  Chemicals  to  the  General  Public"  to  the  Commission5.  In  the  following 
sections,  this  Report  will  summarise  the  main  findings  of  the  study,  compare  them  to  other 
similar reports provided by internationally recognized organisations (UN, UNITAR, etc.) and 
draw conclusions on whether an amendment of the CLP Regulation is justified or not. 

3. Findings on communication of information on chemicals to the general public 

3.1. Recognition and understanding of CLP pictograms and other label elements 

The  surveys  conducted  for  ECHA's  study  emphasized  that  the  levels  of  recognition  and 
understanding  of  the  new  hazard  pictograms  differ  considerably  from  one  Member  State  to 
another, and that there is generally little understanding of the safety measures that need to be 
taken when using chemical products.  Besides, they showed that most respondents felt only 
moderately  informed  or  not  well  informed  about  the  hazards  associated  with  chemical 
products.  

In  particular,  the  Eurobarometer  Survey  has  shown  that,  in  the  EU  as  a  whole,  the  most 
common means of determining whether a chemical product is hazardous, is to read the safety 

5 
http://echa.europa.eu/documents/10162/13559/clp_study_en.pdf 

The study is available at ECHA website: 

4

 
 
 
 
 
 
 
 
 
                                                 
instructions. This has been confirmed for the products perceived as most hazardous, such as 
pesticides and insecticides (50 % of respondents always read safety instructions before using 
them).  By  contrast,  for  other  product  categories,  such  as  car  care  product  and  household 
detergents, less  than  one third  of respondents declared to read  the  safety  instructions before 
use.   

The second survey on risk perception stressed that the correlation between risk perception and 
safety behaviour is rather low. This means that risk perception is not per se a sufficient driver 
for safety behaviour. On the contrary, emotional behaviour and past experience seem to play a 
much more important role. 

According  to  the  feedback  from  the  two  above  mentioned  surveys  considered  in  ECHA's 
study, some new hazard pictograms are well recognised by the general public (see Figure 1), 
whilst others are not.   

It is important to recall that many of the new pictograms introduced by the CLP Regulation 
are rather similar to the existing labels under the previous EU legislation; for some the only 
visible difference is the background colour (orange in the old labels, white in the new) and the 
shape (square in the old pictograms, a red diamond in the new CLP pictograms). 

Figure 1: New CLP pictogram for Flammability and the previous one, very high recognition by 
general public (over 80%). 

Likewise,  the  meaning  for  the  pictograms  with  a  similar  predecessor  is  often  correctly 
understood (see Figure 2). 

Figure 2: New CLP pictogram for 'Explosives' and the previous one, very high understanding 
by general public (over 80%) 

Not  surprisingly,  the  new  CLP  pictograms,  that  have  no  similar  'predecessor'  under  the 
previous EU legislation, are scarcely known or understood by the general public (see Figure 
3).  

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Figure 3: New CLP pictogram for 'Serious Health Hazard', not present previously, very low 
recognition and understanding of its meaning by the general public (respectively 20% and 
12%). 

However, in some specific cases the findings were rather surprising: 

• 

• 

the  new  'exclamation  mark'  pictogram  (see  Figure  4)  was  familiar  to  59%  of  those 
interviewed,  despite  the  fact  that  it  had  no  similar  predecessor  in  the  EU  system. 
However,  the  meaning  (Health  Hazard)6  was  understood  by  only  11%  of  the 
interviewees. 

the meaning of the 'skull and crossbones' pictogram (see Figure 5) was understood by 
only one third of those interviewed, whilst other studies showed a much higher level 
of understanding7.  

Figure 4: New CLP pictogram for Health Hazard, familiar to 59% but understood by only 11% of 
general public. 

It is believed that the familiarity with the symbol derives from the fact that people see the exclamation 

6 
mark in different contexts e.g. in road signs. 
7 
Environmental research 108 (2008) 419-427 and Spanish National Consumer Institute Project "Product 
Safety. Pictograms Safety and danger" 2011. It should be noted, though, that in the ECHA study consumers were 
asked directly to indicate the meaning and were not provided with a list of possible choices, which could have 
been the case in the other studies. 

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Figure 5: New CLP pictogram for Acute Toxicity and the previous one, low comprehension by 
general public (33%). 

Regarding  the  signal  words,  the  Eurobarometer  survey  indicated  how  the  word  "danger"  is 
generally considered stronger than the word "warning" by most people in the EU. However, 
results  in  a  few  Member  States  were  different,  which  emphasises  that  standardisation  and 
translation  across  the  27  European  Member  States  with  many  different  languages  remain  a 
challenge. 

Finally, no direct findings have been provided on the comprehension of hazard statements and 
precautionary  statements.  Therefore,  due  to  the  importance  of  those  elements  in  the  hazard 
communication, further investigations should also assess the level of understanding for hazard 
and precautionary statements. 

3.2 Need for awareness raising activities and training 

The first clear outcome from the levels of recognition and understanding of CLP Pictograms 
is that awareness-raising activities are needed to enhance the general public’s recognition and 
understanding of the new CLP labels.  

It  should  be  noted,  though,  that  the  new  labelling  is  currently  only  mandatory  for  chemical 
substances,  while  most  of  the  chemical  products  sold  to  the  general  public  are  actually 
mixtures,  for  which  the  CLP  Regulation  will  apply  from  1  June  2015.  Nonetheless,  it  is 
important  to  increase  public  awareness  and  promote  the  understanding  of  hazard  labels  and 
associated safety measures. 

According  to  the  findings  in  ECHA's  study,  awareness-raising  activities  need  to  take  into 
account  national  hazard  perception  patterns  and  should  be  targeted  at  the  general  public,  as 
well as at specific audiences such as families, single households, school children, etc. using a 
variety of didactic means (web pages, leaflets, audio-visual material, etc.). 

In fact, perceptions of the hazards pertaining to certain chemical products differ considerably 
between  Member  States  and  also  between  different  population  subgroups  within  the  same 
Member  State.  Consequently,  communication  and  awareness  raising  activities  will  need  to 
address  national  audiences  in  a  differentiated  manner,  taking  into  account  language  barriers 
and adequate communication channels, e.g. smart media applications, social media.  

More generally, those activities should be targeted to: 

• 

refresh knowledge/ familiarise the public with the new pictograms and the signal 
words; 

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•  encourage the general public to actually read the label and consider the pictograms, 

• 

hazard and precautionary statements to raise awareness; 
inform about the possible consequences of wrong handling of hazardous products in 
order to reduce a false sense of safety. 

Awareness-raising  activities  need  to  be  tailored  to  the  institutional  capacities  and  available 
resources of the public and private bodies involved. They should also be adapted to various 
settings, with targeted messages available for instance at points of sale, public spaces, schools 
or homes. 

Among the target groups children are probably one of the most sensitive and they should be 
well  informed  about  the  hazards  of  products.  Specific  educational  material  will  have  to  be 
developed  for  distribution  in  schools  –  some  Member  States  are  already  undertaking  such 
activities8. 

Both, for the preparation and conducting the study, ECHA relied on extensive consultation of 
the Agency’s Risk Communication Network (RCN) established in autumn 2008. One role of 
the RCN is to establish a mechanism for the exchange of information, experience, case studies 
and  good  practice  among  those  in  charge  of  coordinating  risk  communication  in  REACH 
Competent Authorities (MSCAs) and ECHA. Thus, the network may help members to meet 
their communication needs vis-à-vis the general public on risks and the safe use of chemicals, 
avoiding  conflicting  messages  from  public  authorities  and  establishing  best  practice  in  risk 
communication.  

Furthermore,  ECHA's  regular  contacts  with  MSCAs  and  their  CLP  experts  as  well  as  its 
outreach to national CLP helpdesks (via the HelpNet network of national REACH and CLP 
helpdesks)  puts  the  Agency  in  a  good  position  to  sustain  and  coordinate  awareness  raising 
activities with regard to CLP.  

3.3. Product appearance and hazard information on the label 

ECHA's study revealed that messages regarding the hazards of a chemical product expressed 
explicitly or inherently through its packaging may override the messages contained in a CLP 
label.  For  instance,  all  the  following  factors  may  influence  significantly  the  perception  of 
hazards: 

• 

• 

the shape and colour of packaging (i.e. red/black colours versus green/white colours) ;  

the  presence  of  “innocence”  related  visual  elements  on  a  product  (for  example, 
pictures of a child, a mother, a flower, a tree etc.);  

•  brand recognition and appreciation;  

•  understanding  a  product  to  be  more  “natural”  than  industrial  through  ambiguous 

visual elements (pattern of wild animals, forest etc.). 

ECHA's study recommends that industry should be encouraged to bring product appearance 
and packaging more in line with the hazard information on labels, making use of behavioural 

ECHA's Risk Communication Network is the institutional forum for the exchange of Members States 

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experiences in the field of communication on the safe use of chemicals 
http://echa.europa.eu/en/web/guest/about-us/partners-and-networks/risk-communication-network 

8

 
 
 
 
 
 
 
 
 
                                                 
drivers to amplify the label’s message, thereby promoting the appropriate safety behaviour in 
consumers. In fact, according to ECHA, an attractive package should not seduce a consumer 
into ignoring or taking too lightly the warnings that the CLP Regulation has made mandatory. 

Therefore,  efforts  to  align  the  'messages'  regarding  product  hazards  from  packaging 
appearance and label content can be a potential avenue for raising awareness and  improving 
behaviour  on  the  safe  use  of  chemicals.  Authorities,  manufacturers  and  distributors  could  – 
through  voluntary  joint  public-private  action  –  seek  to  promote  self-regulatory  steps  in  this 
regard  (to  be  noted  as  there  are  already  some  ongoing  initiatives  where  industry  has 
undertaken voluntary information campaigns to increase users’ awareness and encourage the 
safe use of their products9).  

Finally,  it  should  be  considered  as  well  that  previous  studies  carried  out  on  consumer 
perception of hazards warnings have indicated that consumer attention can be diverted by too 
much information on a label regarding all potential hazards10. In contrast, warnings focused 
on  specific  hazards  (as  pictograms)  may  enhance  attention  and  thus  increase  consumer 
protection.  

Therefore,  potential  amendments  of  the  requirements  for  labelling  should  focus  on 
simplification  of  contents  and  layout  improvement,  rather  than  propose  to  add  further 
information.  

3.4. A new analysis after 2015 

As  outlined  previously,  both  field  surveys  provided  feedback  on  the  recognition  and 
understanding (or lack thereof) of the main risk communication elements and individual CLP 
pictograms.  Their  findings  show  that  some  hazard  pictograms  are  hardly  known  or 
understood.  

This is not surprising given that the provisions of Title III and IV of the CLP Regulation on 
“hazard  communication  in  the  form  of  labelling”  and  “packaging”  only  took  effect  with 
respect to individual substances on 1 December 2010 (see Article 62 of the CLP Regulation).  

In addition, the vast majority of chemicals products used by consumers are actually mixtures 
containing several substances. The CLP provisions will be mandatory for mixtures only as of 
1  June  2015.  During  the  transitional  period,  the  previous  system  of  labelling  and  hazard 
pictograms  for  mixtures  (Directive  1999/45/EC)  continues  to  apply.  Consumers  will, 
therefore, continue to see mainly the old pictograms on chemical products they buy. 

Given that Article 34(1) of the CLP Regulation set a deadline of 20 January 2012, ECHA’s 
study  had  to  be  conducted  somewhat  prematurely,  with  the  Eurobarometer  Survey  being 
conducted  already  at  a  time  (between  November  and    December  2010)  when  the  general 
public had hardly encountered the new hazard pictograms in real life. When the “qualitative 
research” (in July 2011) undertook to gather more information, the obligation to use the CLP 
pictograms for labelling and packaging substances had only been in effect for less than a year, 
whilst mixtures were still labelled almost exclusively under the previous legislation. 

9 
http://www.cleanright.eu/ 
10 
Study on Comprehensibility of labels based on Directive 88/379/EEC on Dangerous preparations, 1999 
European Commission DG III;  UN GHS 4th Revised Edition, 2012 Annex 5 Consumer Product labelling based 
on the likelihood of injury. 

9

 
 
 
 
 
 
 
 
 
 
                                                 
Therefore, it seems appropriate to re-visit the level of understanding of European citizens at a 
later date, when their experience and acquaintance with the pictograms will have developed, 
preferably after the CLP pictograms also become obligatory for mixtures. A new analysis of 
the  impact  of  the  CLP  pictograms  on  EU  citizens’  behaviour  and  understanding  should  be 
undertaken some time after June 2015. 

4. Conclusion  

In the light of the findings of ECHA's study conducted in accordance with Article 34 (1) of 
the  CLP  Regulation  and  other  studies  on  the  same  matter,  changes  to  the  CLP  pictograms 
themselves are not recommended as it is more beneficial to allow the public to get used to the 
new  global  system,  steadily  improving  the  overall  understanding  of  the  hazards  posed  by 
chemicals and encouraging a safer use of household chemicals in particular. 

Considering  also  that  a  proposed  change  of  the  CLP  pictograms  would  require  the  re-
negotiation of the relevant GHS provisions established in a multilateral UN context, there is 
currently no benefit in altering the label conventions. Instead, at this juncture, the emphasis of 
activity needs to be placed on awareness-raising and knowledge-promotion. 

Consequently,  the  Commission  considers  that,  at  this  point  in  time  a  legislative  proposal  to 
amend the CLP Regulation is not justified and recommends that: 

•  awareness raising activities should be prepared and conducted to enhance safe use of 
chemicals  by  EU  citizens  coordinated/promoted  by  the  ECHA's  risk  communication 
and helpdesk networks – preferably in the run-up to the deadline as of which the CLP 
labelling obligations will apply to chemical mixtures (1 June 2015); 

•  manufacturers  and  importers  could  be  encouraged  to  bring  product  appearance  and 

packaging more in line with the hazard information on labels; 

•  contents  simplification  and  layout  improvement  on  substance  and  mixture  labels 
should  be  promoted  (for  instance  providing  further  guidance  on  omitting  certain 
information elements and on precedence rules); 

•  a  further  analysis  of  the  understanding  of  the  safe  use  of  substances  and  mixtures  is 
conducted  some  time  after  1  June  2015  (also  hazard  and  precautionary  statements 
should be considered). 

10