Online Retailers Violate Labeling Obligations

As part of random sampling control, the Norwegian Environment Agency found that 11 of 15 online retailers did not make the legally required disclosures when their products contained hazardous chemicals. In a press release (available only in Norwegian), the director, Bjørn Bjørnstad, criticized the violation. Although the companies have corrected the problem in the meantime, Bjørnstad emphasized the importance of regular monitoring in e-commerce.

The legal basis for the labeling obligation is the CLP Regulation [(EG) No. 1272/2008] that took effect in September 2009. The defining part of the regulation is Art. 48, Sections 1 and 2. Those section define how products are to be labeled. The article also creates requirements for advertising such products. The requirements include online sales because customers usually do not have the ability to read the classification sticker on the product before closing a contract. That means that online retailers must list hazard classes on the Web site. Since June 2017, they have had to do the same for mixtures.

You can find valuable tips in the CLP Broschure (available in German only) of the Chemical Industry Association. If you have additional questions, we are pleased to help at

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