Newsflash: CLP Label font size problems continue

23rd November 2023

Dear Friend,

Way back in January 2023, I wrote about the proposed new labels under EU-CLP (which also affects NI CLP labels, but will not affect GB-CLP labels). At the time of writing, 23rd November, we are waiting to hear the outcome of the trilogue sessions on the EU-CLP legislative act, but a serious issue has arisen which I need to inform you about even before the trilogue is completed.

The story so far

We at TT Environmental were, frankly, horrified about the original proposed minimum font sizes, which had been slipped into the proposed CLP Legislative Act at the last minute, without any industry discussions. In our view, they were unworkable.

The proposed new minimum font size for labels were:

• Packages not exceeding 3L – Minimum font = 8pt
• Packages Greater than 3L but not exceeding 50L – Minimum font = 12pt
• Packages Greater than 50L but not exceeding 500L – Minimum font = 16pt
• Packages Greater than 500L – Minimum font = 20pt

The spacing between lines of text must be equal to, or above, 120% of the font size (e.g. for 20pt, line spacing must be 24pt).

Later on in the year, the Legislative Act went to committee in the European Parliament, and there was some excellent lobbying work from the trade associations, and an alteration to the font size proposals was announced, along with the line spacing minimum requirements being dropped. The amendments were only published in late September.

However, the new proposed font sizes were given in mm, rather than in points. This meant that we were dealing with two different units.

Being industrial chemists rather than typography specialists, we thought that the new heights in mm referred to the overall height of the text itself, and that the font size issue had been resolved.

We reported this in our 29th September newsletter, incorrectly, as:

Minimum font sizes for labels are coming in:

• Not exceeding 3 litres: 8pt/1.4 height in mm
• Greater than 3 litres but not exceeding 50 litres: 12pt/1.8 height in mm
• Greater than 50 litres but not exceeding 500 litres: 16pt/2.4 height in mm
• Greater than 500 litres: 20pt/3.0 height in mm

So we stopped making a fuss about this issue – also incorrectly, as it turns out.

Problem #1, spotted by Hibiscus

This week, Tracey Hemingway-Wright, one of our friends at HIBISCUS PLC. Chemical Labels | Chemical Labelling / SDS Software, spotted that the units in our newsletter item were inconsistent, and that we needed to translate between points and mm of text.

If you are familiar with typography, you’ll know that this is not necessarily an easy thing to do, as different fonts can be different sizes – in fact we think the reason the European Parliament switched from font size to mm of text is to avoid people choosing very small fonts.

Problem #2, spotted by us

So I went back to the EU Parliament proposed amendments to see if I could work out what was going on, I spotted that we had omitted a very important piece of information, which is that the height in mm refers to the x-height of the text, and not the total height of the text.

Now, if you’re not familiar with the term x-height (and it isn’t defined in the amendment to the CLP legislative act), it’s a typography term meaning “the height of a lower-case x letter”.

As far as I can tell, x-height has been chosen as a way of differentiating sizes between fonts because x is an average lower-case letter which doesn’t have descenders or ascenders or a slightly higher or lower top line (as some letters may have subtle differences for readability).

What we should have said in our newsletter

Our newsletter information should have read:

• Not exceeding 3 litres: 8pt/1.4 x-height in mm
• Greater than 3 litres but not exceeding 50 litres: 12pt/1.8 x-height in mm
• Greater than 50 litres but not exceeding 500 litres: 16pt/2.4 x-height in mm
• Greater than 500 litres: 20pt/3.0 x-height in mm

I would like to apologise profoundly for the omission of the term x- from the 29th September newsletter, as it was unintentionally misleading.

The difference between x-height and overall text height are obviously quite large. So when we thought that the font heights had been reduced significantly, it turns out that they may have been reduced by much less than we realised.

So what’s really going on with proposed EU-CLP label font sizes?

It turns out that it’s actually quite difficult to translate between point sizes and mm height, never mind mm x-height. There are actually all sorts of things to consider like the “em”, the text dimensions within the em, different definitions of point size between the EU and UK/USA etc (there’s some useful information on these terms here https://en.wikipedia.org/wiki/X-height and here https://en.wikipedia.org/wiki/Em_(typography) if you’re really interested)

So the easiest way to look at what’s going on is to pick a standard font, which Hibiscus said should be Helvetica, and compare the point sizes with the x-heights, and have these both in mm.

We printed out a Helvetica 20 point label on A4, which enabled us to put all of the information on a single “label”. (This is of course, twice the minimum label size for a 500 litre and above package).

As far as I can measure, the x-height is 3.5 mm (plus or minus 0.25 mm!). The x-height for a 500 litre and above package is 3 mm. So the reduction in font size for the largest label is approximately 1/7th, which is not anywhere near as significant as we had hope for.

(The reduction ratio may be even smaller for smaller font sizes, although I don’t have the correct micrometer handy to be able to measure this). And instead of the minimum text height being 3mm, it’s actually more like 7mm (measured d to g)!

To be fair to the EU, the new proposals do work, up to a point, as these A5 labels demonstrate (all measurements estimates – please do your own research):

However, the benefits are mainly due to row height reduction, rather than font size. I’m also not very happy with the layout on either of these labels, as they are less readable than a current label would be. And the proposed amendments clearly won’t help for products with more hazards and/or pictograms.

As we suspected, we’ve had the wool pulled over our eyes by the European Parliament amendments to font sizes.

What we thought was a significant difference in font size is actually very little, at least between point sizes and the x-heights in mm for Helvetica, and this is likely to be the case for other fonts.

What this means for EU-CLP labels if minimum font sizes are imposed

As you might expect from the result above, the proposed minimum font sizes don’t really help much. The removal of the minimum line spacing does provide some relief, but it’s not going to help every product which is currently labelled legally.

This is particularly important for any packages where there is a limited area for the CLP label to sit, whether that’s smaller packs, or IBCs where there’s only around an A4-sized flat surface for a dual Transport/CLP label.

So we are effectively back to square one, where we are being pushed into providing larger labels for hazardous products; or where we will need to use fold-out labels. Despite the fact that these changes do not increase the readability of the label at all, as Alison Potts explained in our original post in January.

In fact, if x-height becomes the standard font measure, we could see people changing fonts to ones which have shorter ascenders and descenders, to give more space on the label, but at the expense of readability.

Other behaviours which might occur include removing kerning and reducing space between words; or using narrow fonts, both of which will squish letters together and also impact adversely on readability.

What can be done about this?

At the moment, the CLP Legislative Act is still going through the trilogue process. As far as I am aware, this means that it can be changed without further reference to the European Parliament, and the original font size proposals could be reinstated; the new ones brought in; or some third option could be introduced.

I would urge all of the trade bodies to lobby the committees who are involved in the EU-CLP trilogue to drop any reference to minimum font sizes. There is no evidence that it is a problem – the issues identified by the EU themselves relate to consumer interpretation of information, not readability. Minimum font sizes are not required within GHS; it goes against ECHA’s own minimum size guidance (1.2mm font size minimum, regardless of pack size); and it will create a great deal of trouble and expense for the EU and NI chemical industry, and any countries like GB selling into those jurisdictions, without adding to the safety of the end user.

If you are in the EU or GB chemical industry, please bring this issue up with your trade bodies, and let’s see if we can get this ridiculous proposal dropped, although the trilogue process is due to end by 6th December, so we only have a brief window to act.

Otherwise I think all that will happen is we’ll have a couple of years of wasted cost and effort before it has to be removed on workability grounds.

Kind regards,

Janet Greenwood

TT Environmental Ltd

PS Tracey Hemingway-Wright has checked the exact proposed font sizes for Helvetica in Illustrator, and she has discovered that, for this particular font, the following proposed point sizes apply (but remember we are still waiting for final confirmation from the EU on the exact text of the CLP Legislative Act):

• 3L , x-height 1.4mm, 7.6pt font size in Helvetica
• 3-50L, x-height 1.8mm,  9.7pt font size in Helvetica
• 50-500L, x-height 2.4mm,  13pt font size in Helvetica
• 500L+, x-height 3mm,  6.3pt font size in Helvetica

Thanks again to Tracey and her colleagues at HIBISCUS PLC. Chemical Labels | Chemical Labelling / SDS Software for all their help and expertise.