DanGoods
Training & Consultancy Limited
86 New Forest Drive, Brockenhurst, Hampshire SO42 7QW
Tel: +44(0)1590622015 Fax: +44(0)1590622232
E-mail: Info@DanGoods.co.uk Web:www.DanGoods.co.uk
VAT Registered number: 731 6338 44
BRIEFING
Child Resistant Closure (CRC)
Introduction
Child Resistant Closure is a device required to be present on the immediate
packaging (e.g. bottle or tube or carton) of certain dangerous/hazardous
chemicals (substances or preparations/mixtures) supplied to the general public
in order to act as a last line of defence against the possibility that a child may
accidentally ingest the contents.
Regulatory Basis in European Community
In the European Union (EU) the requirement to have a CRC on the immediate
packaging of certain dangerous/hazardous chemicals is found in:


For substances in the Regulation (EC) No 1272/2008 on classification,
labelling and packaging of substances and mixtures (known in short as
“CLP”)
For preparations (now often known as mixtures) until 1 June 2015 in the
1999/45/EC Dangerous Preparations Directive (DPD)
For mixtures (formerly known as preparations) from 1 June 2015 latest,
or earlier if voluntary decision is taken to supply classified, labelled and
packaged in accordance with CLP before 1 June 2015
A CRC is required for substances, and any mixture supplied that is classified,
labelled and packaged to CLP, if the substance or mixture is:


Acute toxicity Categories 1, 2 or 3
Systematic Target Organ Toxicity – Single Exposure Category 1
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


Systematic Target Organ Toxicity – Repeated Exposure Category 1
Skin Corrosion Category 1
Aspiration Hazard Category 1, except where such chemical is supplied in
an aerosol dispenser or a container fitted with a sealed spray attachment.
Or if a mixture and contains:
 3% or more methanol
 1% or more of dichloromethane
Note: The CRC is required whatever the capacity of the packaging. It is
understood that this only applies to the packaging immediately holding the
chemical, and not to any higher layers of packaging.
A CRC is required for preparations that are not yet classified, labelled and
packaged in accordance with CLP but are classifiable under the DSP with the
following INDICATIONS OF DANGER (not same as symbol letter allocation):
•
Very toxic
•
Toxic
•
Corrosive
Also any preparation assigned the Risk Phrase R65, except where such chemical
is supplied in an aerosol dispenser or a container fitted with a sealed spray
attachment.
Further any preparation that contains (by weight):•
•
.
3% or more methanol
1% or more of dichloromethane
The requirements for the CRC ‘construction’ for packages of substances and
mixtures supplied classified, labelled and packaged in accordance with CLP is set
out in Part 3 of Annex II of CLP.
This requires CRCs of reclosable packages to comply with ISO standard EN ISO
8317, as amended.
Non-reclosable packages shall comply with CEN standard EN862, as amended.
Conformity can only be certified by labs conforming to standard EN ISO /IEC
17025, as amended. Note: If “it seems obvious that packaging is sufficiently safe
for children because they cannot get access to the contents without the help of a
CRC Briefing – June 2013
Page 2 of 3
tool” then testing does not need to be performed (eg a non-ring-pull baked bean
can).
For preparations still classified, packaged and labelled in accordance with the
DPD the same technical requirements are applicable.
Notes:
For aerosols if required, which would be rare, the CRC would be part of the
protective cap design.
Prepared by
Desmond WAIGHT
DanGoods Training & Consultancy Ltd
January 2006
CRC Briefing – June 2013
Page 3 of 3