ARE VACUUM CLP PICTOGRAMS ALLOWED ON THE LABELS OF SUBSTANCES AND DANGEROUS MIXTURES?
The CLP does not explicitly prohibit the use of blank pictograms or strikethrough on the label, although article 19 (1) says:
“1. The corresponding pictogram or pictograms of danger shall appear on the label, intended to transmit specific information about the hazard in question.”
And Article 25 (3) says:
“3. The supplier may include in the supplementary information section of the label other information in addition to those mentioned in sections 1 and 2, provided that they do not hinder the identification of the elements of the label mentioned in article 17, paragraph 1, letters a) ag), and offer more details and do not contradict or question the validity of the information specified by said elements.”
ECHA recognizes that the pre-printing of labels is a common practice in the industry and recommends that in these cases the pictograms that may remain empty are overprinted in black so that they are completely hidden and can not contradict or question the information of the rest of the label.