CLP and empty diamonds: what’s the right approach?
  • There is a lot of confusion over the fact that people think 'empty diamonds' are not permitted under CLP; however, no where in the regulation is this stated. The issue is causing a huge debate. We are hopeful that the issue remains undefined as there are few alternatives to not having unpopulated diamonds for GHS as colour printers capable of producing International Maritime Dangerous Goods (IMDG) compliant labels are not readily available and are very limited in their capability.
  • In my view it is important that industry should ensure that their MS experts are left in no doubt that the 2nd ATP to CLP, which is under progress, should clarify that there is no objection to having an empty red framed dimaond.
  • It is and was a practice that under DSD/DPD the orange square sometimes was empty as well and nobody really asked for it, now where the problem with placing the squares is huge and the practice to use preprinted label will not really work anymore for thermo transfer printers, the industry likes to get a result where they will no be happy with I guess. The red squares are no problem for the laser color printers on blank label.

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