Digital labelling of EU fertilising products

Suggested useful references about digital labelling Compiled by: Dr. Koen Van Keer, Regulatory Affairs and Labelling Manager, Yara International ASA / Yara Belgium (29-05-2023) The attached document is not aiming to present a complete and detailed overview and analysis of the state-of-the art of digital labelling.

AssoFertilisers, the National Fertilisers Association, which is part of Federchimica-Confindustria, brings together the main Italian fertiliser operators, with a total turnover of around EUR 1 billion, representing over 90 % of the Italian market.

Filed in Italian · English published by the European Commission

Article 6 of the fertilizer products regulation should be supplemented with a provision stating that labelling can be done physically on the packaging or accompanying documents, digitally, or both. The detailed regulations regarding this are made in the new Articles 11a, 11b, and 11c. When packaged goods are provided to economic operators (traders), labelling can be done physically or digitally.

Yara position on the Commissions Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2019/1009 as regards the digital labelling of EU fertilising products Notice to readers (27/05/2023): This position is drafted from the perspective of a global mineral fertiliser manufacturer (Yara International ASA).

AFAÏA, the French Federation representative of companies supplying the fertilizing materials and innovative inputs of sustainable crops (growing media, mulches, organic soil improvers, organic and organo-mineral fertilisers and biostimulants) and gathering over than hundred marketers thanks the European Commission for giving the opportunity to comment on the Regulation draft amending Regulation (EU) 2019/1009 as…

Fertilisers Efficiency Enhancers (FEE), a sector group of the European Chemical Industry Council (Cefic), welcomes the opportunity to provide input to the proposal for a Regulation regarding the digital labelling of EU fertilising products.

EBIC welcomes the Commission proposal on optional digital labelling. EBIC calls for the introduction of a criterion for professional users versus non-professional users, so that digitisation for products intended for professional users can become a reality. As it stands, the proposal on digital labelling does not go far enough, and most EBIC members would not invest in creating digital labels.

Mr LUNIFA welcomed the proposed regulation on the digital labelling of fertilising products. The introduction of this option for fertilising products is beneficial: — for the environment: this reduces the amount of waste (e.g. when changing the information on the label). — for users: they may have more legible and accurate information than on labels of limited format.

Filed in French · English published by the European Commission

Fertilizers Europe welcomes the Commission's proposal for a Regulation concerning the digital labelling of EU fertilizing products (2023/0049). The introduction of digital labelling on fertilizing products has multiple potential benefits: not only does it have the potential to reduce waste, but it also represents an effective tool to provide a greater quantity and quality of information.

The National Association of Fertilizer Manufacturers (ANFFE) welcomes the publication of the proposal for the regulation on voluntary digital labelling of EU fertilizer products and asks the Commission to implement as soon as possible the regulation of the technical requirements and the information that can be included in the digital label.

PhosAgro is the leading producer of environmentally safe phosphate fertilisers. We welcome the occasion to provide feedback on a proposal for a regulation on the digital labelling of fertilising products. We support the initiative to modify the EU Fertilising Products Regulation (EU) 2019/1009 so as to introduce new labelling requirements to create a voluntary digital label in annex III.

The Commission aims to improve the communication of labelling information and provide economic operators the flexibility to opt for the rules that are most appropriate for their specific products. In principle, this approach is heavily supported by industry including K+S as it may help save resources and costs, contribute to sustainability and facilitate communication.

Packaging size: while we recognize the voluntary nature of using a digital label and the requirements set in Regulation (EU) No 142/2011, we would like to emphasize that many end-users receive products in 1m3 (or larger) bigbags or 1 m3 IBCs. Due to the density of many fertilisers the weigth of these containers exceed the 1000 kg mentioned in consideration 9 of the proposal.

The Quality Association Substrate für Pflanzen e.V. (GGS) and the Industrieverband Garten e.V. (IVG) welcome the initiative on the digital declaration of fertilising products under the FPR. The differentiation of digital labelling in relation to target groups also seems useful, as this takes account of different levels of knowledge.

Filed in German · English published by the European Commission

Good morning. The principle is well overall. However, I find it aberrant to use digital labelling, even though it is necessary to print information on the packaging or affix a NFC or other chip which will be complicated to reprocess for selective sorting. Or a code that can erase and see access for useless digital etiquettes. This is a double investment for manufacturers.

Filed in French · English published by the European Commission

The proposal for digital labelling under the new European Union Fertiliser Regulation, now submitted, still contains many requirements of a physical nature, in particular the labelling of fertilising products from trade to farmer and packaging companies for horticulture.

Filed in German · English published by the European Commission

The Danish Consumer Council thanks the Commission for the opportunity to comment on the Inception Impact Assessment on the simplification and digitalization of labels on chemicals. We believe that consumers need more information, not less. And the consumers need the information at point of sale.

The Union des Industries de la Fertilisation (UNIFA) welcomes the European Commission’s initiative to digitise labels for the fertilising products sector. It is already difficult to declare all the labelling elements required under the current Fertilisers Regulation (EC) No 2003/2003, Regulation (EC) No 1272/2008 (CLP) and the international agreements on the transport of dangerous goods (e.g. ADR/RID).

Filed in French · English published by the European Commission

Borealis L.A.T welcomes the option of digital labelling for EU fertilizing products; we herewith also support the submissions from our associations, German IVA and Fertilizers Europe. Less plastic waste and better – site specific – fertilizer use by farmers are the potential, mutual benefit of this new technology.

Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products) Inception Impact Assessment (IIA) We welcome and support proposals to improve the usefulness of labelling for consumers and professional users. However, user safety should not be compromised in the process of making labelling more user-friendly.

The Downstream Users of Chemicals Co-ordination group (DUCC) welcomes any initiative that aims at improving protection, while fostering investment that can be justified from an economic, social, and environmental perspective for a digital transition. DUCC members are keen to engage with stakeholders on priority information to leave on packaging and supplementary information to be made available online.

On behalf of Groquifar, Association of Chemical and Pharmaceutical Wholesalers, in Portugal, I appreciate the possibility to have our say about this matter. Our associates must comply with several EU Regulations (REACH, CLP, Biocides), and all related with Agrochemicals and Pharmaceuticals, which is why we give our full support to improving communication on chemicals having in mind a safe and sustainable use of…

EuroCommerce, the principal European organisation representing the retail and wholesale sector, welcomes the opportunity to provide feedback to the roadmap for the simplification and digitalisation of labels on chemicals, and specifically the CLP Regulation, the Detergents Regulation and the Fertilising Products Regulation.

The Federal Environment Agency appreciates the initiative of the European Commission to improve the communication with consumers in order to reduce harmful effects of hazardous chemicals on human health and the environment. In order to achieve this objective, we are of the opinion that all information relevant to the consumer's purchasing decision and the correct use should be labelled on the packaging.

ChemSec thanks the Commission for the opportunity to leave comments to the Inception Impact Assessment on the simplification and digitalization of labels on chemicals. ChemSec agrees with the general idea of creating a harmonized digital labeling system for chemical product information.

DI welcomes the possibility to submit our feedback on the EU Commission Inception Impact Assessment on “Simplification and digitalization of labels on chemicals (CLP, Detergents, Fertilising Products)”. In general, DI is in favor of the initiative on the simplification and digitalisation of the labels that should lead to clearer hazard communication on human health and environment both to consumers, professional and…

IKEM – Innovation and Chemical Industries in Sweden welcome the initiative to increase digitalization of labelling information in order to provide clearer, better and more targeted information to downstream users. Please see the attached document for our detailed views on the inception impact assessment.

Slovak competent authority for CLP would like to thank the Commission for providing the roadmap - „Chemicals – simplification and digitalisation of labelling requirements“ and for the possibility to comment on it. In our opinion chemicals’ and detergents’ labels are overloaded with many information resulting from different pieces of legislation, sometimes with duplicities of information.

Comments from IBMA DA: The Federation of Organic Plant Protection Products Manufacturers in Germany and Austria represents companies that produce, authorise and distribute biostimulants and plant protection products of biological origin. The active substances and ingredients may be covered by the CLP Regulation, so member companies are affected by the revision.

Filed in German · English published by the European Commission

•CropLife Europe welcomes the European Commission initiative on simplification and digitalisation of chemical labels and is pleased to share its initial thoughts. •Labelling requirements for Crop Protection products in Europe are defined in two regulations: the Classification, Labelling and Packaging Regulation (EC) No 1272/2008 and the Plant Protection Product Regulation (EC) No 1107/2009 which results in complex…

CEPE welcomes the opportunity to provide some initial thoughts on the Inception Impact Assessment (IIA) launched by the European Commission (EC) in July 2021. Role of the label One common denominator amongst all chemical products sold in the EU is that they have a label attached to them.

FEICA welcomes the European Commissions’ initiative on simplification and digitalisation of labels on chemicals to better communicate essential information about chemical products to users via innovative digital tools, and thanks the Commission for the possibility to provide feedback.

We appreciate EC initiative and the possibility to have our say. Members of our association are committed to providing consumers and professional users with the information ensuring a safe and sustainable use of products. To the products that are in our area of activity apply several EU Regulations: Detergents, CLP, Biocides and REACH.

FEIQUE, the Spanish Chemical Industry Business Federation (www.feique.org) appreciates the opportunity to comment on the European Commission’s inception impact assessment on “Simplification and digitalisation of labels for chemicals (CLP, Detergents, Fertilisers)”.

Filed in Spanish · English published by the European Commission

CESIO believes that the labelling requirement for surfactants requiring the “identification of the surfactant group and percentage on the packaging“ can be removed, because it does not give more useful information to consumers. There should no longer be a need to distinguish in Detergents labelling between groups of surfactants (i.e.

Hello, Please find attached the note from the French authorities on the preliminary consultation of the European Commission on simplifying and digitising the labelling of chemicals (CLP, detergents, fertilising products).

Filed in French · English published by the European Commission

Association of Chemical Industry of the Czech Republic agrees, that chemicals´labels are overloaded with information, making them difficult to read and understand, especially for consumers (eg. new introduction of UFI code on the labels of some chemical mixtures). We support therefore simplification and streamlining of labels under CLP and Detergent Regulation.

AssICC, the Italian Chemical Trade Association, represents companies engaged in the distribution of chemical products both of substances and of mixtures. Please find enclosed our comments on the European Commission’s “Inception Impact Assessment” Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products) Ref.Ares (2021) 4554631-14/07/2021.

Filed in Italian · English published by the European Commission

A clear simplification of the labelling rules would be the legalisation of multilingual folding or tag labels in times of globalisation. Multilingual folding/tow tags in all EU languages would: — simplify supply chains; — support sustainability (saving of air-conditioned storage areas, etc.) — shorten transport routes (the same product can also be sent to and used in a neighbouring country) — Promote the free…

Filed in German · English published by the European Commission

Hazard and precautionary statements take quite a big area from the label so we suggest that they could be included in the digital content whereas other CLP regulations would be kept in the physical label. It is not financially viable to make a customized label in each country, which leads to the situation where H- and P-statements are added to the label with all the different languages (usually in a very small font…

Cefic, the European Chemical Industry Council (www.cefic.org) welcomes the possibility to comment on the EU Commission Inception Impact Assessment on “Simplification and digitalization of labels on chemicals (CLP, Detergents, Fertilising Products)”. This feedback focuses on the CLP regulation.

The Italian Federation of Chemical Industry strongly welcomes this initiative from the European Commission. Simplification and digitalization can contribute to improving efficiency, efficacy and safety. There are many advantages that it’s necessary to take into account: • Digitally stored labelling texts can be updated promptly.

BEUC welcomes the Commission’s intention to improve the means of communicating essential information on chemical products to consumers. As observed in the Inception Impact Assessment (IIA), product labels are too often overloaded with information, making them difficult to read and understand for consumers.

The European Mortar Industry Organisation (EMO) strongly supports using digital means for supplying relevant product information. In our sector, it is common practice to print all mandatory (regulatory) information, but also all necessary/relevant information for the final preparation and use of the product a priory on the packaging, which is ordered in large amounts.

The British Coatings Federation is the sole UK trade association for manufacturers of decorative coatings, printing inks, industrial coatings and wallcoverings, representing a £4 billion value industry and the interests of over 200 member companies.

From the point of view of consumer protection, it is very problematic to transfer information on products from the label to the internet. Information on the internet is much less retrieved than it can be read directly on the label. As a result, transparency for consumers is degraded and makes it more difficult to make informed purchasing decisions.

Filed in German · English published by the European Commission

Association for Finnish Paint Industry supports the comments made by CEPE and emphasizes the following. We agree with the Commission conclusion, that there is room for improvement to better communicate essential information about chemical products to users, particularly consumers, and that the use of innovative digital tools on product labels could improve the communication.

Motip Dupli GmbH thanks the EU Commission for this initiative and for opening this consultation. We support the proposals of the Commission for simplification and digitalisation of labels. Generally, we support the reduction of content of the physical label of consumer products because this will increase the readability and result in a better understanding by the consumer and, therefore, increase the safety.

In connection with the ongoing consultation process presented by the European Commission on the roadmap for simplifying and digitising labelling requirements, on behalf of the chemical industry, we would like to point out that, in our view, the initiative to simplify and digitise chemical labels, although well founded, requires a very cautious and differentiated approach.

Filed in Polish · English published by the European Commission

The Verband Chemiehandel e.V. (VCH) welcomes the possibility of providing feedback on its assessments as part of the European Commission’s initiative. Please see our opinion in PDF format in the attached file. (complimentary close)

Filed in German · English published by the European Commission

The Spanish National Association of Fertilizer Manufacturers (ANFFE) wishes to provide the following comments on digital labelling: -It is a very good idea that part of the label could be included in digital form, because otherwise the information may not fit in the label, also taking into account that it is written in several languages.

The Polish Detergent Industry Association (PSPKD) welcomes the European Commission’s efforts to simplify and digitise chemicals labels. For the detergent industry and ultimately the consumer, this is one of the most important initiatives, addressing the difficulties and legislative inconsistency encountered in the labelling of detergents.

Filed in Polish · English published by the European Commission

Dear Sirs, I represents Fertiberia, the Spanish fertilizer producer. My comments in line with Fertilizers Europe and with ANFFE (National Spanish Association) are: 1) We support digital labelling due to the volume of information required now by the new Regulation and CLP, etc 2) We consider digital labelling permite to save packaging costs, 3) We think digital labelling facilitate the management of changes in the…

The manufacturers of household detergents (“detergents”) represented in the German Association of Household Detergents (IKW) welcome the European Commission’s initiative to simplify and digitise labelling rules.

Filed in German · English published by the European Commission

Executive summary. The Verband der deutschen Lack- und Druckfarbenindustrie e.V. (VdL) supports a ‘simplification’ and, as a result, improved legibility of labels by allowing certain label elements to be displayed digitally instead of having to be written on the label. The evaluation of possible simplifications should cover the CLP Regulation, the Detergents Regulation and the Biocidal Products Regulation.

Filed in German · English published by the European Commission

Concerning substances and mixtures to be used by consumers, the GHS is only used in the European Economic Area (EEA) and very few countries outside the EEA. The Fitness Check of the most relevant chemicals legislation (excluding REACH) found that labels are overloaded with information, especially for consumers.

The European Commission is considering how to improve communication on chemicals. The focus is currently on detergents and fertilizers. In this context, the labelling requirements for these categories of chemical products could be streamlined and digital labelling could be used.

VdMi basically supports the use of digital labels, as they offer many options for providing the user with important information in a targeted and uncomplicated manner (see also our position paper file). However, some aspects must be taken into account, especially in the area of very small packagings, in order to really achieve a simplification and not just produce additional effort for the manufacturers.

Summary: The European detergent industry, represented by A.I.S.E., strongly welcomes this initiative from the European Commission. We are committed to providing consumers and professional users with information to ensure the safe and sustainable use of products. For consumers, there is evidence, supported by a scientific publication, that current labels do not succeed at adequately conveying this.

Hello, On the labels for end users, there would be: (1) Simplement of the majority ingredients: The ingredients that the emergency services need to know in order to intervene. (2) In addition to pictograms, Phrases H and P must be used: Hazard and precautionary statements + emergency number. Currently, we need to read the SDS, the simple one, is to have the product information.

Filed in French · English published by the European Commission

— Simplification of the label is absolutely necessary, as information on chemical labels is currently overcrowded. Information on the label shall be limited to the most essential information (e.g. CLP marking). Other information (e.g. additional label elements due to specific rules) should be made available digitally.

Filed in German · English published by the European Commission

I welcome any initiative to simplify and streamline labelling requirements, especially in connection to digital labelling. However, we must keep in mind that the labelling of chemicals in the EU is regulated by CLP Regulation, which should be based on UN’s Globally Harmonized System (aka GHS).

This initiative will not only improve efficiency but also safety. As a manufacturer of printers we are distributing many different inks in all Europe, but limited volumes don't allow us to customise the labels for each country and national languages. Adding notices in every language is costly but also not very effective because users throw them away.

Growing media producers are allowed to put products and blends on a harmonized EU market, under the Fertilizing Product Regulation EU 2019/1009. The required demands for labelling of these types of products (Growing Media / Soil Improver) are extensive and require the exact mix to be individually labelled. Growing Media as a base for plant cultivation and propagation is sold within the EU to all member states.

Digital labelling by using a QR code or any other system which is linked to a website (via e.g. a smartphone or other devices) with detailed information or further languages respectively, shall be allowed even in case of small packaging (=< 125 ml) and of multilingual labels.

(1) While we welcome this initiative proposed by the EU, we believe that it falls short if it is intended only to be applied to detergents and fertilisers for use by the general public, as we believe it should be extended to all products affected by CLP for use by the general public (detergents, solvents, paints, insecticides, disinfectants, etc.).

Filed in Spanish · English published by the European Commission

Most important with digitalisation of labelling aspects is the "standard". You really do not want that consumers/professionals need to use different ways of digitalisation between different productgroups eg. a barcode reading app for detergents and a QR-code website link for paints. Digitalisation is all about standardisation throughout all productgroups.

To whom it may concern, labels are overloaded with information. A simplification would be very welcome. However, this initiative should not be limited to CLP regulation, Detergents regulation and Fertilising Products Regulation, but include all EU-regulation and maybe even consider national regulations, which demand information on or next to the CLP-hazard label.For example, the Biocide Product Regulation (Article…

Ludits where the ones who first tried to stop digitalization. We have a huge problem with labelling, as of today, because we have too much information and it's now being disregarded by consumers. Only a "phygital" label can allow indexation, search for specific themes, for key words, redirect to Poison Centres, and provide clear and visual instructions on how to handle products (including how to dispose it at the…

The Global Harmonised System of Classification and Labelling of Chemicals (GHS) must really take into account known environmental hazards! Plastic in the form of industrial raw material (powders up to granules) is not identified as ‘Dangerous for the environment’, although this is widely known.

Filed in French · English published by the European Commission

The German association of fertiliser mixers has the following comments on the labelling in the new EU Fertiliser Regulation: In order to ensure acceptance and implementation by the user, the product should be labelled as easily as possible. This applies in particular to packaging and documents to be handed over to the consumer.

Filed in German · English published by the European Commission