The increase in demand for hand sanitiser during the COVID-19 pandemic has seen some businesses such as distilleries and breweries pivot to produce hand sanitiser products to cater for the demand. Suppliers across the hand sanitiser supply chain (i.e. from manufacturers and distributors to wholesalers and retailers) should ensure that the packaging and labelling on their hand sanitiser products avoid confusion and do not compromise the safety of these products.
The packaging of some hand sanitisers has raised concerns as some new entrants in the market are using packaging resembling food or beverage products. Hand sanitiser ingestion cases reported to state poison information centres have predominantly involved children ingesting hand sanitiser that resembled a drink product.
For example, the ACCC is aware of some hand sanitisers being supplied in plastic bottles with a pop-top lid, which resemble children’s drink bottles. The familiarity of packaging may result in children or even adults ingesting the contents. The risk of harm is linked to the amount ingested per kilogram of body weight.
The below advice to suppliers provides suggestions for safer containers and dispensing mechanisms.
- Avoid supplying hand sanitiser in packaging that resembles any type of consumable product (e.g. drink bottles, wine and spirit bottles, food pouches, or aluminium cans).
- Some hand sanitiser products also appeal to children due to their size and similarity to existing children’s products. Consider discontinuing the use of this type of packaging immediately.
- If you operate a distillery, brewery or winery and are using your pre-existing packaging when supplying hand sanitiser, consider if the packaging could be modified so it can be easily distinguished from your usual products.
- Ensure your containers are of an acceptable quality, durable and safe (e.g. no sharp edges).
- Consider child-resistant packaging for the hand sanitiser products you supply, and ensure there are warnings alerting consumers to the hazards to young children (for more information on warnings, see Labelling below)
- According to the Therapeutic Goods Administration (TGA), if the hand sanitiser you manufacture and supply is one of the two formulations set out in the TGA Exclusion Determination, be aware that from 1 July 2020, manufacturers of hand sanitisers made in accordance with the Exclusion Determination are required to ensure that their products are not presented for supply in a way that is likely to result in their products being mistaken for or confused with food or beverages. Manufacturers cannot supply any existing stock that does not comply with the Exclusion Determination after 30 June 2020.
- Consider fitting your packaging with a pump or similar mechanism, especially for volumes greater than 100 ml. For smaller quantities, a press-cap style closure which is hard for children to open and use may be appropriate.
- Avoid using screw-top bottle caps, pull tops and packaging in aluminium cans. Seek alternative safer packaging (e.g. if using a screw-top bottle cap, consider making it child resistant).
- Use bottles that require the consumer to apply pressure to extract the hand sanitiser, either by squeezing the bottle or tipping the bottle over (e.g. some form of flow restriction), instead of a bottle that allows for free flow of the contents.
Products should be clearly labelled as hand sanitiser with the appropriate ingredients label, depending on the type of hand sanitiser you are supplying (i.e. therapeutic or cosmetic).
Below are some key labelling requirements, including a suggested warning label:
- Modify the product label so that your hand sanitiser product can be easily distinguished from your existing products and is clearly recognised as being hand sanitiser. For example, while it can still have your logo and the same font as your other products, consider changing the background to a different colour to reduce the likelihood of the product being confused with consumable products you supply.
- Ensure the words 'hand sanitiser' are displayed in a large font and are one of the most prominent features on the packaging. To implement this, consider tailoring the prominence of other elements of the label such as the company logo and other branding elements.
- In addition to meeting the requirements of the Cosmetics ingredients labelling mandatory standard (including that all ingredients must be listed and need to appear in descending order calculated either by mass or volume), consider providing other information about your product that would be helpful for consumers in making an informed purchasing decision. This may include the percentage of alcohol present in the product or whether the product is based on the WHO formulation.
- Avoid bright colour schemes and imagery that may be appealing to children.
- Consider including the following warnings on your product:
- Keep out of reach of children.
- Children should not use this product unsupervised.
- For external use only, do not swallow.
- If ingested, contact the Poisons Information Centre (13 11 26).
- Flammable – keep away from fire.
- Discontinue use if skin irritation develops.
- In addition to the above warnings, consider using globally-recognised warning symbols for hazardous and flammable liquids.
- Ensure any warning labels are conspicuous, in contrasting colour to the background and fixed securely, or directly stamped on the product.
Other safety considerations
- Only certain TGA-approved hand sanitisers and those that have been made exactly to the WHO formulation can make certain claims such as being hospital grade or being suitable for use in medical or health centres.
- Products containing alcohol are also regulated as hazardous chemicals and are regulated under state and territory work health and safety laws. This includes that products must not be presented for supply in a way that is likely to result in them being mistaken for or confused with food or beverages.
- Hand sanitisers that are general consumer goods should not make false or misleading claims relating to their effectiveness to kill specific viruses such as COVID-19.
- In addition to warnings on the product label, look into other ways to inform consumers that these products are hazardous to children if ingested and that they should be kept out of reach of children. This may include providing information at the point of sale in-store or online, and through any post-sale communication such as direct mail or your business’ social media channels. The ACCC has published some tips for consumers on the safe use of hand sanitiser.
- Remember that the label and packaging are both forms of advertising and should not be misleading or deceptive.
- If you are a retailer, consider the height at which these products are displayed in retail stores and assess the likelihood of them being accessed by children in the store.
Managing the risk of previously-supplied hand sanitiser
For products that you have already supplied to customers, you may wish to conduct a recall and, as part of the remedy, offer to provide consumers with an alternative dispensing mechanism and/or revised labelling that can be added to the current packaging.