8 July 2016
Irish Inspection Reminds all Manufacturers of EU-Wide Packaging Requirements for Liquid Laundry Detergent Capsules
On 9 May 2016, the Irish Health and Safety Authority (HSA) launched an inspection campaign targeting retailers and distributors of liquid laundry detergent capsules, generally known as “liquitabs”. The aim of the campaign is to ensure that all of these liquitab products comply with additional EU-wide safety measures, which came into full effect on 1 January 2016.
In Ireland (which has a population of around 4.64 million), there have been over 900 incidents involving liquitabs reported to the National Poisons Information Centre at Beaumount Hospital in Dublin, Ireland in the last five years. The majority of these involved children less than three years old. The HSA is the competent authority for enforcing these regulations in Ireland. A senior inspector with the HSA recently outlined the changes and the requirements for retailers:
“[Liquitabs] are small and colourful, so children can mistake these capsules for toys or sweets. Changes to the labelling and packaging regulations were introduced to make it more difficult for children to see and access the product and prevent accidental exposure. We are now asking all retailers and distributors to check their existing stock to make sure what they have on their shelves is compliant as all non-compliant stock should be removed.”
The launch of the inspection by the HSA in Ireland presents an opportunity to remind all Hong Kong manufacturers of EU-marketed liquitabs of the precise legal requirements for the packaging of such products. Since 1 January 2016, all liquitab products sold on the EU market must comply with the new additional safety measures. In particular, these new legal requirements prescribe precise conditions for the packaging of single-use liquitabs which cover both the outer packaging and the inner soluble capsules:
First, manufacturers must ensure that outer packaging:
i. is opaque or obscures the visibility of the liquitabs,
ii. states “Keep out of reach of children” in a visible place and in a format that attracts attention,
iii. is contained in an easily reclosable, self-standing container,
iv. is fitted with a closure mechanism which impedes the ability of young children to open the outer packaging by requiring coordinated action of both hands with a strength that makes it difficult for young children to open,
v. and, further, maintains the closure functionality under conditions of repeated opening and closing for the entire life span of the outer packaging.
Second, manufacturers must ensure that the soluble packaging containing a single-use laundry detergent:
i. contains an aversive agent (such as a bittering agent) to cause an immediate oral repulsive effect within a maximum time of 6 seconds, in case of accidental oral exposure,
ii. retains its liquid contents for at least 30 seconds when placed in water at 20°C, and
iii. is capable of resisting mechanical compressive strength of at least 300N under standard test conditions.
The rules were first introduced by the European Commission in December 2014 in response to the high number of exposures involving young children reported to poison centres across Europe. A transitional period up to 31 December 2015 was put in place for products already on the market and to allow manufacturers, distributors and retailers time to comply with the change in regulations.