GHS/CLP Regulations – Revision to Label Specifications
On November 24, 2024, the European Union released Commission Regulation 2024/2865, which modifies the EU CLP Regulation. These modifications came into effect on December 10, 2024, with most of the provisions becoming compulsory by July 1, 2026, while the remaining changes will be enforced starting January 1, 2027.
The regulation brings a range of important revisions to the Classification, Labelling, and Packaging (CLP) Regulation, focusing on enhancing chemical safety and keeping pace with changing market trends. A key update includes the introduction of new labelling standards, specifying minimum font sizes, line spacing, and formatting requirements.
Proposed Obligatory Formatting Rules
The new formatting rule for labels are:
- The text must be printed in black and the background of the text should be white;
- A single font must be used that is easily legible and without serifs;
- The letter spacing must be appropriate for the selected font to be comfortably legible;
- The distance between two lines must be equal, or above, 120% of the font size – for example, a 20 point size font must have leading (line spacing) of 24 point, or above;
- The font size of regulatory information must be as the following table, dependent on package capacity.
Measuring Font Sizes
When measuring fonts, we don’t usually deal with the metric measurement system – typographic units are measured in points and font sizes are usually measured from the top of the ascender to the bottom of the descender – this is the full font height/size.
Previously, the EC have specified the changes to font sizes in points, however, the latest amendments to text sizes are specified in x-height (the height of the lower-case x) in millimetres. This is probably because it is more practical, in real-life instances, to measure in millimetres rather than points, and also because the X-height of fonts differ from one font to the other.
The point size of a font includes 3 main parts:
X-HEIGHT – the height of the lowercase “x” character.
ASCENDERS – lines that extend above the base “x” character (as with ‘h’).
DESCENDERS – lines that extend below the base “x” character (as with ‘g’).
It is important to note that all fonts DO NOT have the same the x-height – even when they are the same point size. The x-height of fonts can vary considerably, and this can have a great affect on the readability of the text. Lowercase letters in fonts with larger x-heights, such as Veranda and News Gothic appear larger on the whole and are easier to read.
The following shows three different fonts: all fonts are shown at 20pt, but all have different x-heights.
The height of the ascenders and descenders in relation to the x-height of characters also differs from font to font.
For chemical labelling, the text ‘tracking’ (space between letters) and ‘horizontal scale’ (width of letters) should not be reduced as this will make text much harder to read, especially at a distance.
Converting x-height in mm to point size
Converting the point size of fonts to millimetres is not as simple as it would seem, and this is without factoring in the x-height of letters.
Strictly speaking, the term ‘font size’ is misleading, since we don’t define the size of the font when setting the point value in software applications such as Word or InDesign, but rather we specify the body height. Historically, in manual typesetting, the body height was defined by the height of the lead type block on which the actual font face, the printing surface of the type, was moulded. When Gutenberg set a 12pt font, it was the metal type block and not the printed letter that had a vertical height of 12 points. Hence, the body height is generally bigger than the printed character.
In the age of digital type, the body height is now known as the ‘Em’ and is still an important measure reference in font design – when you enter a 12 pt font size in Word, you define the height of a character’s bounding box which corresponds to the height of the metal body the type was cast on in the days of lead typesetting.
A point is equal to 1/72 of an inch or 0.3527 mm, or 1.333 pixels. 72 points = 1″. Because millimetres and inches are measurements of physical items, they are not suitable to use with digital based applications, so for digital, the pixel the smallest unit used to measure font sizes.
Common fonts at the mandatory sizes
When producing chemical labels in-house, or using labelling software, a non-serif font must be used (a serif is a decorative line or taper added to the beginning and/or end of a letter’s stem, such as in the ‘Times’ font).
Common sans-serif fonts used in the chemical industry, include: Arial, Avenir, Calibri, Frutiger, Futura, Gill-Sans, Helvetica, Myriad Pro, News Gothic, Open Sans, PT Sans, Trebuchet and Veranda.
The attached chart shows these common fonts converted from mm x-height to point size, for the given package capacities.
Measuring Leading (Line Spacing)
Leading, the vertical space between lines of type, is measured from the baseline of one line of text to the baseline of the line above it (see the font diagram above). The baseline serves as the invisible line on which most letters sit.
As per the new CLP label formatting rules, the distance between two lines must be equal to, or greater than, 120% of the font size. For instance, a font size of 20 points requires leading (line spacing) of 24 points, or more.
Implementation Deadlines
The new font sizes, formatting, and line spacing applies to labels from 1st January 2027.
There are also two transitional provisions that apply.
- By 1st July 2028 (Article 61(7)): New CLP rules apply to substances and mixtures placed on the market before 1st July 2026.
- By 1st January 2029 (Article 61(8)): New CLP rules apply to substances and mixtures placed on the market before 1st January 2027.
How Can Hibiscus Help?
Hibiscus, offers a full range of support services, including consultations with Dangerous Goods Safety Advisers (DGSA), ensuring your business stays up to date with regulatory changes and maintains full compliance.
By choosing Hibiscus as your partner, you can be confident that your labels not only adhere to existing requirements but are also prepared for future regulations.
Our ‘Enterprise’ chemical labelling software offers an x-height tool for accurate text scaling and a 120% line spacing option to improve readability and layout, making it simple to meet the latest CLP labelling standards.
Find out how we can improve your hazard communication compliance – Call us today: 0113 242 4272
