The new Dangerous Preparations Directive (DPD, 1999/45/EC) introduces a spe
cial labelling requirement for skin sensitizers in products that are regula
ted under this Directive. The packaging of products containing greater than
or equal to0.1% of a sensitizer must bear the inscription "Contains 'name
of sensitizer'. May produce an allergic reaction." The aim is to protect in
dividuals already sensitized by providing information which enables them to
avoid products containing ingredients which may elicit their allergy. Howe
ver, this is only of benefit where such sensitized individuals do exist in
the population. Moreover, this labelling requirement does not take into acc
ount the potency of the skin sensitizer. For each sensitizer and type of sk
in exposure, there will be levels below which it will not elicit allergic c
ontact dermatitis reactions in individuals who are sensitized to that chemi
cal. We therefore propose that within the new DPD, it should be possible to
override this labelling requirement with well-documented data, to ensure t
hat information provided to the consumer on the product label is not mislea
ding. The current implementation in the DPD of what is in principle a good
idea means that further action (legislative changes; scope for derogation)
is needed if the potential benefits are not to be lost.