COPR: Label guidance

Action for approval holders

If you are the approval holder of a biocidal product under the Control of Pesticides Regulations (COPR), you are responsible for ensuring it is packaged and labelled in accordance with the Schedule which forms part of the COPR Certificate of Approval and:

• in Great Britain (GB), the GB Classification, Labelling and Packaging of Substances and Mixtures (GB CLP) Regulation
• in Northern Ireland (NI), the EU Classification, Labelling and Packaging of Substances and Mixtures (EU CLP) Regulation

Find out more about CLP.

Your label must not describe the biocidal product in any way which is misleading in relation to:

• the risks to human health
• the risks to animal health
• the risks to the environment
• its efficacy

Phrases that are considered to be misleading and must not be used include:

• low-risk
• non-toxic
• harmless
• natural
• environmentally friendly
• animal friendly
• any similar terms

Label elements

Labels must be in English and the text should be shown clearly and indelibly.

Products approved under COPR must contain certain information within a single lined box, known as the statutory box, on the label.

Products approved under COPR for use by more than one user group eg for amateurs and professionals, must have separate labels for each user group.

Label elements inside the statutory box

The following elements of the Schedule must appear on the labels for your COPR product inside the statutory box:

• restriction of use phrase given in section 3.1 of the Schedule eg:
  • FOR USE ONLY AS AN INSECTICIDE
• application rate given in section 3.1 of the Schedule
• statutory box phrases given in section 3.1 of the Schedule ie:
  • Read all precautions before use
  • HSE No. XXXX
  • Users must comply in full with all their legal responsibilities under the Control of Pesticides Regulations 1986 (as amended), including complying with all Conditions of Approval
• risk mitigation measures for the professional product label (if applicable) ie:
  • FOR USE ONLY BY PROFESSIONAL OPERATORS

Label elements outside the statutory box

The following elements of the Schedule must appear on the labels for your COPR product outside the statutory box:

• product name given in section 1 of the Schedule
• risk mitigation measures given in section 3.1 of the Schedule and marked with an asterisk (*) for the relevant users (for example):
  • only the amateur use risk mitigation measures should be included on your amateur use product labels
  • only the professional use risk mitigation measures should be included on your professional use product labels
• name, address and telephone number of the marketing company named in the Approval Notice
• pack size – nominal weight or volume
• user advice phrase given in section 3.1 of the Schedule (for example):
  • To avoid risks to man and the environment, comply with the instructions for use
• contents statement given in section 3.1 of the Schedule – the name(s) and concentration(s) of each active substance in the product
• other restrictions relating to use given in section 3.3 of the Schedule – usually only relevant for antifouling products
• classification, including hazard and precautionary statements, in accordance with:
  • GB CLP in GB
  • EU CLP in NI
• batch number and expiry date

In some cases, it may be physically impossible to put all of this information on the label (this might be due to the size or the function of the biocidal product). The label elements listed below must always appear on the label:

• product name
• contents statement – the name(s) and concentration(s) of each active substance in the product
• two of the statutory box phrases:
  • Read all precautions before use
  • HSE No. XXXX
• classification, including hazard and precautionary statements, in accordance with:
  • GB CLP in GB
  • EU CLP in NI

Other label elements may instead appear on an accompanying leaflet that is integral to the packaging.

Packaging

Products may only be supplied to end users in:

• pack sizes up to the maximum size listed in section 3.1 of your COPR Schedule
• packaging types declared to HSE – a reference to the communication where this information was provided is given in section 3.1 of your COPR Schedule

Advice on packaging and labelling

When you apply for product approval under COPR, you will be required to submit details of the packaging and the draft label which will be considered as part of the assessment process.

Packaging will only be considered in terms of whether the size and type is within precedent for the product type.

Labels will only be considered in terms of whether they correctly and appropriately describe the product eg:

• label claims are within precedent for the product type
• terms such as non-toxic, natural, environmentally friendly etc are not used

Labels will not be considered in terms of other aspects of the label, such as marketing or graphics, unless it impacts on the key information.

HSE does not approve, authorise or endorse labels under COPR – the responsibility for the content and accuracy of labels remains with the approval holder.

Advertising

COPR sets separate requirements for the advertising of biocidal products – you can find these in Regulation 6(a) (or Schedule 1) of COPR itself.

Additional advertising requirements will also apply – these are set by:

• the GB Biocidal Products Regulation (GB BPR) in GB
• the EU Biocidal Products Regulation (EU BPR) in NI

Find out about the BPR advertising requirements.