Lab-HB-Vol-3-Amateur
Lab-HB-Vol-3-Amateur
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
111
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
APPENDICES 127
112
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
1.2 Volume 1 of this Handbook provides guidance on requirements for all product
labels.
1.3 This Volume 3 sets out additional requirements on how text on an Amateur
Product Label must be presented. It is divided into several sections as follows:
Section 2
Product Identity
Safety CLP labelling Section 3
Information Safety Precautions Section 4
Medical Advice Section 5
Instructions for Use Section 6
1.4 An example of a draft amateur label including Product Identity, and Safety
Information is given in Appendix 3. Examples of Instructions for Use are at
Appendix 8
Important note
The requirements and phrases listed below are the most up-to-date for a product
authorised under Regulation 1107/2009. If your product was approved under
COPR 1986 or PPPR 1995 on 14 June 2011 when the new Regulation came into
force, then the previous labelling requirements will continue to apply unless we
have issued an amendment authorisation until or we have reassessed your label
in any future application.
113
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
2. PRODUCT IDENTITY
2.1 Introduction
Product Identity is not a specific discrete section on the label but consists of
various information about the product and its use which will ensure that it is easy
to identify what it is, what it contains and how it should be used.
• product tradename
• product registration number
• authorisation holder and marketing company details
• formulation type
• amount and name of the active substance(s)
• net quantity of product
• product batch number/ date of manufacture
• Product use-by date
• biological use phrase
• statement of users obligation in following label instructions
• ‘Use Pesticides Safely’ warning
The information included in the Product Identity must appear on the Container
Label and on any separate Leaflet supplied with the product and must be
formatted in line with the requirements detailed below and those set out in
Volume 1.
114
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
This is the unique 5 digit identifying registration number given in the authorisation
(currently prefixed with ‘MAFF’ or ‘MAPP’ depending on when we first allocated to
a product) and this must appear in close proximity to the product tradename.
Where appropriate, this may appear on the back packaging label above the
‘Safety Information’ as an alternative to stating the product registration number on
the front packaging label.
If your product registration number is currently prefixed with ‘MAFF’ this will be
amended to ‘MAPP’ when the next authorisation for that product is issued.
The name and address of the authorisation holder, and if different, the name and
address of the marketing company must appear.
A telephone number for the authorisation holder and/or the marketing company
must also appear. If there are 2 different companies in these roles then you can
choose to have both telephone numbers or just one. However, in any case the
number must be a suitable contact number for users to obtain advice on the use
of the product or report adverse incidents.
The name and content of each active substance, as specified on the Notice of
Authorisation, must be given (usually included in a single ‘contents statement’
with the formulation type - see 2.6 above).
115
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
Important Note
Labels for all organophosphorus and carbamate products require the following
phrase to be included after the name of the active substance on the Main Area of the
container label:
The net quantity of the preparation in the container must appear (in accordance
with the Weights and Measures Act). Where a number of smaller containers are
packaged within a single outer, the outer should state how many, and what size,
of the small packs are being supplied (this may be printed on the container itself
rather than on the label area).
Important Note
The pack size of amateur products is limited to the maximum that would be used in a
typical garden in one season as this helps to ensure that most products are used up
within 1 or 2 seasons. In addition the maximum allowed for any concentrate product
is 1 litre or 1kg. Larger sizes may be acceptable for ready-to-use products
depending on the packaging design.
The formulation batch number (or some means of identifying it) plus the date of
manufacture must appear (this may be printed on the container itself rather than
on the affixed label area).
An appropriate ‘use-by date’ must appear if the 2 year storage stability data
evaluated for authorisation indicates an acceptable shelf-life of less than 2 years.
Brief statement on biological use (for example ‘For the control of aphids and red
spider mites on apples).
This statement may use descriptive terms such as kills, controls, repels and
eradicates, but these terms must be supported by appropriate data.
116
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
• WEEDKILLER
• FUNGICIDE
• INSECTICIDE
• MOSSKILLER
• PLANT GROWTH REGULATOR
• ANIMAL REPELLENT
• BIRD REPELLENT
• HORMONE ROOTING POWDER
• HORMONE ROOTING MEDIUM
• LAWN TREATMENT
• ALGAE KILLER
• MITE KILLER
• SLUG KILLER
• SLUG AND SNAIL KILLER,
• SLUG AND SNAIL REPELLENT
All amateur pesticide products must carry the following short message on the front
of the pack:
This phrase should be in bold type, upper case and white text on black
background. The font type should be Helvetica Neue Bold Condensed.
• For a pack with a front facing label under 100mm wide, the minimum font
size should be 9pt.
117
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
• For a pack with a front facing label between 101-200mm wide, the
minimum font size should be 13.5pt.
• For a pack with a front facing label over 200mm wide, the minimum font
size should be 18pt.
Links to images for label printing can be found on the HSE website.
Full details of the use of the ‘Child/Pet Logo’ on amateur product labels are set
out in section 5.7 of Volume 1 and in Regulatory Update 03/2010.
118
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
3.1 Introduction
3.1.1 Plant protection product (PPP) labels must comply with legislation on
classification and labelling of chemicals under the Classification, Labelling and
Packaging (CLP) Regulation 1272/2008. This implements in the UK the United
Nations' Globally Harmonised System (GHS) for classification and labelling.
3.1.2 CLP classification is part of Safety Information and must appear on the Container
Label and on any separate Leaflet supplied with the product formatted in line with
the requirements detailed below and those set out in Volume 1. Only symbols
and phrases which are appropriate to the product must be used. You should
justify your choice of symbols and phrases when making an application.
Guidance on CLP classification and labelling is in the CLP Guidance Document
on our website. This section provides advice on:
(a) How a CLP classification for health effects will determine whether an
authorisation may be granted for an amateur product- see 3.2. below; and
(b) How to format the required CLP information on an amateur PPP label- see
3.3. and 3.4 below.
(a) The product is classified for any of the following health effects under CLP:
(b) Where a risk assessment demonstrates that PPE is required for safe use of
the product. This usually means that products classified as follows are
unlikely to be authorised as home garden products unless our risk
assessment shows safe use without PPE (meaning no exposure when
product supplied in a water-soluble sachet).
119
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
3.3.1 CLP has requirements on the information that must appear on classified
products. However, they do not explicitly specify location and presentation (other
than to define the size and colour of the hazard symbols/pictograms and that
symbols/phrases must be in close proximity. The classification is a fundamental
part of the Safety Information so all information relating to CLP should ideally
appear on the Main Area of the label if space is available.
3.3.2 The basic information under CLP that must appear on any classified product plus
comments is detailed below. Note that in addition to the classification and
labelling components not covered by the PPP Regulation 1107/2009, there is
other required information which duplicates that required by 1107/2009:
120
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
3.3.3 Most of the CLP requirements must already appear on a PPP label and should
continue to appear in the formats given elsewhere in this Handbook.
3.3.4 The phrases and symbols (4, 5 and 7 above) and the formulation constituents (3
above) are the additional CLP information that must appear on the PPP label.
We do not have a set format for presentation of this information but we suggest
that it appear boxed and it must be on the Main Area of the label.
3.3.5 An example of such a ‘CLP box’ is given below. You may utilise any other format
as long as it complies with both the requirements of CLP and the guidance on
PPP labels in this Labelling Handbook.
121
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
Warning
To avoid risks to human health and the environment comply with the instructions for use
3.4 Options if CLP phrases duplicate other phrases required on the label
Some phrases which were historically required on PPP labels in the ‘Safety
Precautions’ are now also specified under CLP (as P statements). Where these
phrases must appear as CLP requirements they need not be duplicated
elsewhere on the label. For example the phrase KEEP OUT OF REACH OF
CHILDREN may have been historically specified as a precautionary phrase on
PPPs, but if it is also a requirement of CLP (P102) and appears in the ‘CLP box’,
then there is no need to repeat the phrase in the ‘Safety Precautions’ section.
You should note that if the phrases differ in any way it may not be appropriate to
delete the phrase from the ‘Safety Precautions’ section. For example if the PPP
authorisation requires the phrase ‘KEEP OUT OF REACH OF CHILDREN AND
PETS’.
Important Note
Phrases historically required under COPR but are not a requirement of CLP s should
remain on the product label to ensure safe use (unless they are identical to a CLP
phrase).
122
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
4. SAFETY INSTRUCTIONS
4.1 Introduction
4.1.2 These may include phrases set out in Annex III to Regulation 1107/2009 (the
‘Annex III phrases’) if the risk assessment has been carried out under that
Regulation (see Volume 2/ Appendix 2*) Such additional phrases must be listed
in the Safety Instructions section.
* Note that we have included the list of Annex III phrases in Volume 2 on
professional products because usually (but not always) they will apply to
such products. One exception is the SP1 phrase ‘Do not contaminate water
with the product or its container’ which must appear in the Safety Instructions
of all amateur products.
4.2.1 The Safety Instructions represent key safety information and should appear on
the Main Area of the label, and any separate leaflet supplied with the product.
4.2.2 It must have a major heading SAFETY INSTRUCTIONS in bold capitals with the
following subheadings in bold using upper and lower text as shown:
The precautionary phrases must appear under the appropriate subheading. Any
sub-heading(s) need not appear if there no required phrases.
4.2.3 The actual safety phrases must be presented as either a mixture of upper and
lower case (as specified in Appendix 1 to this Volume) or alternatively a
combination of bold (in place of upper case) and normal font may be used.
Clarity to the reader is of key importance. We prefer that each phrase appears as
a separate line of text. However, where space constraints dictate, they may
follow on the same line as long as individual phrases are clearly differentiated
from one another.
4.2.4 You must suggest appropriate phrases when submitting the draft label. These
should be based on the assessment for the product/uses, and may consider
phrases used on similar products. We will clarify which phrases are needed after
123
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
we have conducted our evaluation, specifying any changes required via label
amendments issued with the authorisation. To help you decide which phrases
may be appropriate we have provided details of standard phrases and the
situations where they might be used later in this Volume.
124
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
5. MEDICAL ADVICE
5.1 Where the toxicity of the product justifies it, statements on First Aid and Guide to
Doctor or Poisons Centre must appear. This Medical Advice must appear as
appropriate in the Safety Instructions (if a precautionary phrase) or as a separate
section on the Container Label and any separate Leaflet.
125
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
6.1 Introduction
The Instructions for Use section contains all the other authorised text required for
safe and efficacious use. For example crops and pests/weeds controlled, dose
rates, numbers of treatments, timings, (including pre-harvest intervals), mixing and
spraying advice, specific safety and efficacy restrictions or warnings about use.
You should refer to the ‘Crop Definitions List’ guidance on our website for advice
on the appropriate way of defining crops and situations of use when you submit
your draft label.
The Instructions for Use should appear on the Container Label and on any
separate Leaflet supplied with the product. However, where space constraints
dictate, they may appear on the Leaflet only, providing a suitable phrase directs
the user to where they may be found (full guidance on the presentation of
Container Labels and Leaflet is given in Volume 1/ Section 4).
6.3.1 The section must be headed with INSTRUCTIONS FOR USE in bold capitals and
the text underneath should be set normally. For example in capitals and lower
case as appropriate. All subheadings must be distinct from the main
INSTRUCTIONS FOR USE heading.
6.3.2 We prefer standard formats for the Instructions for Use, because this encourages
familiarity of the user with all labels. However we allow some flexibility in format
and have therefore provided some examples to use as a basis for your label.
6.3.3 Instructions and guidance for amateur uses should be written in a way
which may be understood by a lay person. They may need to be simpler than
that appearing on similar professional product labels. However the guidance
given on professional labelling could be used as a starting point as it may provide
useful guidance relevant to the amateur situation. For amateur products,
guidance on doses/application rates may need to be very carefully worded,
especially for products such as slug pellets. The user must be able to determine
the dose without resorting to sophisticated weighing equipment.
6.3.4 It is acknowledged that not all labels can be drafted to fit into a set format. Some
require extensive information whereas others require only brief instructions;
however by adopting a common format, labels should become easier to
understand by the user. The most important aspect is that labels should be
logical and consistent with clear headings and sub-headings.
6.3.5 Two different but acceptable formats are given in Appendix 2 to this Volume.
126
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
a) Direct spray away from ponds and other surface water bodies.
127
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
c) KEEP AWAY FROM FOOD AND DRINK or KEEP AWAY FROM FOOD,
DRINK AND ANIMAL FEEDING STUFFS.
For label clarity, a distinction must be drawn between safety phrases concerning storage
(for example ‘keep out of reach of children and pets’) and those directed at ‘after use’
(for example ‘keep children and pets away from treated area until granules have been
watered in’). Storage safety phrases must be in the ‘storage and disposal’ section of the
label, and the ‘after use’ phrases must be in the ‘Instructions for Use’ section of the label.
4.2 For all amateur products (expect those containing ferrous sulphate alone or
ferrous sulphate + fertiliser):
128
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
4.3 For all amateur products containing ferrous sulphate alone or ferrous
sulphate + fertilizer:
4.5 For all amateur slug pellet products containing metaldehyde, methiocarb or
any other bait-based products of equivalent toxicity (on the front of the
label):
Important Note
It is not appropriate for slug pellets products to have a child/pet logo – see Volume 1/
Section 5.6 for further guidance on the use of artwork.
129
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
1. Format 1
1.1 This is a suggested format for an amateur product which is used to control a pest
or group of pests in one crop or a group of crops where the majority of the
information is the same. It is suggested that the required information be
presented under the following subject headings (or similar) below the main
heading ‘INSTRUCTIONS FOR USE.
• When to use
Details of when to use a product should appear first on an amateur label to
enable users to easily locate the appropriate product for their needs. There
should be a clear statement of the weeds, pests or diseases controlled and
this should be followed by brief general advice on the optimum time to use
the product, for example time of year or plant growth stage.
• Where to use
This section should provide specific information relating to each crop, such
as dose, timings and varieties. This may be achieved with one simple
section (where there is only one crop or where all the crops may be treated
the same), or a number of sections covering the information (for a range of
crops). Alternatively a simple table may be used with general information
appearing afterwards. As a rule this section should follow only one format to
avoid confusion.
• How to use
A section covering mixing and application instructions should appear next.
This section should include information on doses and water volumes (if not
specified for each crop in the crop specific information section), application
methods (for example watering can, sprayer or a particular type of lawn
spreader) and any specific information such as the need to not let the
mixture stand, spray quality (fine, coarse) and advice to clean the applicator
after use. It may be appropriate to include guidance on how to measure or
mark out areas to ensure accurate application.
130
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
Where additional action on the part of the user is required, this should be
detailed. In the case of a mosskiller for example this could include advice on
scarifying and improving drainage. In the case of certain herbicides it could
include the need to wait for a specified period before digging-in weeds or
planting the following crop.
WHEN TO USE
WHERE TO USE
Do not apply to lawns sown or turfed less than six months ago.
Do not apply within three days before or after mowing.
Do not apply under drought conditions, if frost is expected or if the lawn is
waterlogged.
Do not apply in mixture with other weedkillers.
Do not exceed the recommended dose.
HOW TO USE
When moss has turned black, affected areas should be raked to remove
dead moss. Re-occurrence of moss can be minimised by improving
drainage.
Grass clippings must be composted for at least six months before being used as
a mulch.
131
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
2. Format 2
2.1 Relatively few amateur products need to have complex labels (usually there are
not large numbers of uses and instructions). However where the layouts
described in Format 1 above would make the label difficult to write or understand
a tabular format is suggested. An example of where this might be appropriate is
a label for an insecticide used on many crops for the control of a number of
different pests with several crop/pest combinations, each with specific
recommended application regimes.
For all the above crops except strawberry, apply as a fine spray to thoroughly wet foliage but not so that
the leaves are dripping. Wash equipment thoroughly after use.
132
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
For the control of a range of weeds in lawns including moss, dandelion, daisy, plantain and creeping
buttercup.
Field of use phrase.
FOR USE ONLY AS A HOME GARDEN WEEDKILLER
Both may be printed on the container
itself rather than on the label.
Pack size and batch number.
This product covers approximately XXXX square metres. The pack size is limited to what
would be used up in a typical garden
in one season.
Marketing company and/or approval holder details:
Name: XXXXX Statement of users
Address: XXXXX obligation to follow label
Tel: XXXXX instructions.
WHEN TO USE
Product X is applied to control a range of weeds in lawns including moss, dandelion, daisy, plantain
and creeping buttercup. It is most effective when applied to actively growing weeds in the spring.
WHERE TO USE
For use on lawns
Do not apply to lawns sown or turfed less than six months ago.
Do not apply within three days before or after mowing.
Do not apply under drought conditions, if frost is expected or if the lawn is waterlogged.
Do not apply in mixture with other weedkillers.
Do not exceed the recommended dose.
HOW TO USE
Mix 25 ml of Product X in 20 litres of water and apply to 15 m 2 of lawn using a sprayer or watering
can fitted with a fine rose or dribble bar. Ensure complete and even coverage but avoid overdosing.
If rain does not fall within three days, water the lawn lightly. A repeat application can be made after
six weeks if required but do not apply more than twice in any three month period.
When moss has turned black, affected areas should be raked to remove dead moss. Re-
occurrence of moss can be minimised by improving drainage.
Grass clippings must be composted for at least six months before being used as a mulch.
The standard heading and subheadings must appear. Where space is limited the information may be
signposted to a separate leaflet providing a suitable phrase directs the user to where they may be
found.
133
November 2020
Chemicals Regulation Division
Labelling Handbook
Volume 3- Requirements for Amateur Product Labels
Harmful if swallowed
Toxic to aquatic life with long
lasting effects
SAFETY INSTRUCTIONS
Environmental protection
Do not empty into drains
Do not contaminate water with the product or its container
134
November 2020