Guidance

Labelling requirements for regulated poisons and explosives precursors

Updated 11 October 2023

You must label any products you intend to supply to the general public if that product contains a substance above the concentration listed below.

Regulated explosives precursors

Substance Concentration w/w
Hydrogen peroxide 12%
Nitromethane 30% (or 24 % vol)
Nitric acid 3%
Sodium chlorate 40%
Sodium perchlorate 40%
Potassium chlorate 40%
Potassium perchlorate 40%
Sulfuric acid 15%
Ammonium nitrate 16% Nitrogen content
Hydrochloric acid 10%
Hexamine -
Phosphoric acid 30%

Regulated poisons

Substance Concentration w/w
Aluminium phosphide -
Arsenic, its compounds -
Barium, salts of, other than barium sulphate and the salts of barium listed in Part 4 of Schedule 1A) -
Bromomethane -
Chloropicrin -
Fluoroacetic acid; its salts; fluoroacetamide -
Hydrogen cyanide; metal cyanides, other than ferrocyanides and ferricyanides -
Lead acetates; compounds of lead with acids from fixed oils -
Magnesium phosphide -
Mercury, its compounds -
Oxalic acid 10% w/w
Phenols (phenol; phenolic isomers of the following—cresols, xylenols, monoethylphenols); compounds of phenols with a metal 60% w/w of phenols or, for compounds of phenols with a metal, the equivalent of 60% w/w of phenols
Phosphorus, yellow -
Strychnine; its salts; its quaternary compounds -
Thallium, salts of -
Aluminium sulfide -
Sodium sulfide -
Calcium sulfide -
Magnesium sulfide -
Zinc phosphide -
Calcium phosphide -
2-4, dinitophenol and compounds including sodium dinitrophenolate -

Labelling requirements

Products containing substances above the concentration listed must be labelled with the following text:

Acquisition, possession or use by the general public is restricted.

This is in accordance with the Poisons Act 1972.

It is the responsibility of the supplier who intends to make available restricted precursors to the general public to ensure that the restriction is clearly indicated on the packaging. This can be by affixing the appropriate label or by verifying that such a label is affixed.

One simple way to implement this requirement may be through a supply chain collaboration. Commercial contracts between suppliers and retailers could be used to agree that relevant information on the presence and concentration of regulated substances is shared between suppliers and retailers.

The economic operator packaging the product prior to the product’s entry into the market for the general public is best placed to affix the required label.

Further requirements according to EU Regulation 1272/2008 Classification, Labelling and Packaging of Substances and Mixtures

Most of the products that require labelling according to the Poisons Act 1972 will also need to be labelled according to EU Regulation 1272/2008 Classification, Labelling and Packaging of Substances and Mixtures (CLP) due to their inherent hazardous properties.

Article 32(6) of CLP states that:

“Label elements resulting from the requirements provided for in other Community acts shall be placed in the section for supplemental information on the label referred to in Article 25.”

This means labelling required by the Poisons Act 1972 should be placed in the section for supplemental information within the CLP label on products that fall within the scope of CLP.

Example label for hydrogen peroxide, 30%

Non-compliance with the new labelling requirement is a criminal offence.

Any business found guilty of supplying or selling a regulated substance to a member of the general public without first ensuring that a warning label is affixed to the packaging in which the regulated substance is supplied is liable on summary conviction in a Magistrates Court to a fine not exceeding level 2 on the standard scale.