1. Communication to consumers Views/insights from CEPE
Janice Robinson
Director Product Regulations, CEPE
AISE Safe Use Workshop
Brussels, 10 June 2016

2. Concerns of the paint (and AC) industry
Fitting all required information into limited label space, whilst still remaining clear and legible
Increased label elements under CLP, but also requirements from other legislation and own information (instructions for use etc.)
Issue is particularly acute for smaller packages (as in artists’ colours sector)
Multi-lingual labels are a necessity to service customer needs and distribution processes/free movement
Labelling should be meaningful for consumers, not driven by regulatory compliance

3. Example: evolution of labels under CLP
From 11 languages to 6
...but with pictograms smaller than 16 x 16 mm
Need more SKUs to avoid some consumers not receiving advice in their own language

4. Potential solutions
Proposal: use internet technology to enable access to information in many more languages, whilst reducing clutter on labels and drawing consumers’ attention to the most important aspects?

5. Example: CLP + biocides
CEPE is trying to find ‘smart’ ways (within the current legal constraints) to present the labelling requirements of CLP and BPR Article 58(3) without repetition, confusion or bewildering long names
e.g. ‘Contains a biocidal product: Contains C(M)IT/MIT (3:1).  May produce an allergic reaction. Contains a biocidal product for the preservation of dry- film: IPBC. Risk of skin sensitization. Contains a biocidal product: BIT’
Is this clear or helpful to the consumer?

6. Some good news however…
In CEPE’s consumer survey on DIY painting, 70% of respondents said they read the label on the last paint job, and >90% were familiar with the instructions
86% of respondents found the label instructions fairly easy, easy or very easy to understand
Voluntary pictograms are used for paint, but are not standardised as in A.I.S.E.
The above suggests these might not be necessary (but may be nice to have)

7. j.robinson@cepe.org www.cepe.org
Thank you
for your attention