1. Introduction
1.1 The purpose of this letter is to seek your views on proposed new guidance for the labelling of products used in the home and garden by amateur users (so called "amateur products").
1.2 Pesticides approved for use in and around the home and garden are those which the pesticide legislation allows any person to purchase, handle, prepare for use and use without the need for training. Therefore the target audience is very different from that for professional products and the labelling of these products needs to be designed on the basis that the user has limited technical knowledge and requires simple "user-friendly" instructions.
1.3 When the new Labelling Handbook guidance for professional product labels was published last year (see AAHL 26/2002), Part D of the Handbook was empty with the intention of guidance on the requirements for amateur product labels being published at a later stage. With this in mind we have now prepared a draft version of Part D (pdf, 103 pages) which is attached to this letter. This document sets out the proposed format and standard phrases to be used in producing the ‘approved text’ for amateur labels. As well as this new Part D, Parts A, B, E, F, G, H and I of the previously published ‘Labelling Handbook’ also apply, as appropriate, to amateur product labels.
1.4 As with the labelling guidance for professional products, approval holders will be given as much scope as possible in the content and format of the final label whilst at the same time ensuring that all legal requirements are met. However, the main aim is to simplify the label content for the benefit of the user. The proposed changes, listed below, have been done with this in mind but views are welcome as to whether this goes far enough or whether it is possible to simplify labelling even further for amateur users.
2. Proposed changes
2.1 In contrast to the labels for professional products it is proposed that a "statutory area" will no longer be required for amateur products. We feel that, for amateur products, the area serves a limited purpose and that, in any event, users are often confused as to the difference between the "statutory area" and the "directions for use".
2.2 So that the product may be used safely and efficaciously, the product label should give directions as simply and clearly as possible with a clear message as to why the directions must be followed. To this end the guidance will include a requirement for the following phrase to appear on all amateur product labels.
"The following directions will help you to use the product safely and correctly. If you use the product in any other way you could endanger your or others safety and may damage the environment. You should therefore read and follow all directions and safety precautions on the label carefully."
2.3 It is suggested that the ‘approved’ text of the label consists of 3 sections. The content of these sections will be approved by PSD as a condition of ‘Sale and Supply’ and label amendments to the draft texts may be required.
- Product Identity (i.e. trade name, formulation type),
- Safety Information (i.e. Hazard symbols, medical advice)
- Directions for Use (the situations the product can be used in and how to use the product).
2.4 Following the introduction of Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (CHIP 3), which implements Directive 99/45/EC, the product label must (after July 2004) be compliant with CHIP 3, as well as any labelling requirements according to COPR/PPPR. PSD recognise that duplication of identical/similar phrases from the two sets of legislation may cause problems in drafting amateur labels, where space is often limited. We have therefore provided guidance which clarifies what information must appear, and explains where duplication is not necessary.
2.5 Guidance on formatting the Directions for Use for ease of understanding by the user is suggested in the new PART D of the Handbook.
2.6 As explained in para.1.3 above, the existing Parts of the Handbook provide guidance on the final structure of the printed label. Some of these requirements also apply to amateur products. They include information on:
- avoidance of misleading and false information on the label;
- differentiating the label into container-affixed information and leaflets, labelling different parts of packaging and options for labelling ‘novel’ or ‘non-conventional’ packs;
- minimum requirements on legibility of text; (CHIP 3 rules will apply in certain circumstances)
- use of graphics and artwork on final printed labels;
- amendments that may be made to the approved text without recourse to a further application for a new approval (note does not include Company Advisory Information as specified for professional products which should not appear on the label).
2.7 PSD will no longer routinely check compliance with such requirements when considering the draft label for products exclusively sold for the amateur market. It will however be a statutory condition of ‘Sale and Supply’ that the approval holder ensures that the final label complies with these requirements.
3. Next steps
3.1 The views of all those listed on the attached Annex are being sought on these proposals in the first instance. A separate letter is being sent to representatives of amateur user organisations.
4. Deadline for responses
4.1 Please send any comment to Katy Bray at the above address, or e-mail Katy on katy.bray@hse.gsi.gov.uk. We would be grateful for your comments by 17 October 2003, including an indication as to whether or not you would wish to attend a meeting to discuss the proposals.
Yours faithfully
Elaine Close (Mrs)
Pesticides Registration and Enforcement Policy Branch
