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What, if any, are the EU Requirements for Minimum Font Size for a Product's Warning Label?

July 25, 2008
Question 

With regards to non-food consumer packaged goods, is there an EU law stating a minimum font size to be used on the packaging when it is referencing the product's warnings?

Answer 

At the Community level, there is no general rule which requires a minimum font size for warning labels for non-food consumer packaged products. However, certain products can be subject to specific requirements imposed by Community legislation or, in the absence of EC law, to specific rules imposed by the national laws of the Member States where the product is marketed.

In the absence of specific provisions at the Community level regarding the safety of the product concerned, the General Product Safety Directive is applicable. According to this Directive, producers have a general obligation to place on the market only safe products. Producers must provide consumers with the relevant information that will enable them to assess the risks inherent in the product and to take precautions against those risks. Producers also have the general obligation to adequately and effectively warn consumers against risks. Product warnings should be suitable, clearly worded, and easily comprehensible, and they should be available in the official language(s) of the Member State(s) where the product is marketed. In addition to the official language requirement, the European Commission has required in particular cases, that the warning appear in a clearly visible and legible manner and that it be conspicuously displayed on the packaging or attached to the product in such a way that it will be visible to the consumer at the point of purchase.

In the area of non-food consumer products, there are several Community rules that require compliance with specific labeling requirements. These products include textiles, shoes, cosmetics, detergents, dangerous substances, and dangerous preparations, among others. Therefore, whether the warning label is subject to more stringent rules (such as a minimum font size) will depend on the specific product and whether the product is subject to specific Community and/or national labeling provisions.