Changes to the CLP Regulation 2024-2027 and new obligations

The European Commission has published two documents amending Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures – commonly referred to as the CLP Regulation.

  1. Commission Delegated Regulation (EU) 2023/707 of 19 December 2022 amending Regulation (EC) No 1272/2008 as regards hazard classes and criteria for classification, labelling and packaging of substances and mixtures.
  2. Regulation (EU) 2024/2865 of the European Parliament and of the Council of 23 October 2024 amending Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures.

Commission Delegated Regulation (EU) 2023/707

The first document establishes new hazard classes and new classification criteria for chemical substances and mixtures. As a result, the labelling and packaging of chemicals will also change. The regulation has been in force since 20 April 2023, but it contains transition periods to give entrepreneurs time to adapt to the new requirements.

Deadlines for the application of the new classification criteria:

  • 01/05/2025 – new substances placed on the market
  • 01/11/2026 – substances present on the market before the date of implementation of the Regulation
  • 01.05.2026 – new mixtures introduced to the market
  • 01/05/2028 – mixtures present on the market before the date of implementation of the Regulation

The introduction of new hazard classes has some consequences for entities. Therefore, we suggest how to prepare for the changes and what obligations entrepreneurs have:

  1. fulfil classification and labelling obligations by the transitional deadlines set out in the Regulation;
  2. update the classifications and labelling of substances and mixtures in product portfolio;
  3. the REACH registration dossier should be updated with new information;
  4. the C&L notification must be updated;
  5. the safety data sheet of the substance and mixture should be updated;
  6. update the notification to the PCN poison centre;
  7. everyone in the supply chain must be notified of the changes, and appropriately updated documentation must be provided to the recipients.

More information on the new classification criteria: https://ekotox.eu/

Regulation (EU) 2024/2865 of the European Parliament and of the Council

The regulation introduces a number of changes affecting chemicals and comes into force on December 10, 2024. Here also a transitional period has been applied to adapt to the updated regulations. Most of the changes come into force on July 1, 2026, but some of them will take effect six months earlier.

Deadlines for the application

  • 01/07/2026 – These include clarification of the obligation to include the address of the EU/EEA supplier on the label; new rules specifying deadlines for updating labels in the event of a change in classification or label information; use of fold-out labels; introduction of MOCS substances; and many more.
  • 01/01/2027 – requirements for font size and label appearance; new obligations for distributors related to PCN notification.

Label update:

  • 6 months – if the classification or labelling of the substance or mixture changes, resulting in the addition of new hazard categories or a stricter classification, or if additional information is required on the label;
  • 18 months – if there are any other changes in the classification or labelling of the substance or mixture.

* If the substance or mixture is subject to detergent or biocidal product legislation, the effective dates specified in the relevant legislation shall prevail.

The amendment to CLP contains a number of important changes, including:

  1. the address of the European operator on the product label who is responsible for the correct labelling of the product in accordance with the CLP Regulation;
  2. updating the classification rules and implementing EU Regulation 2023/707, including labelling the mixture with new hazard classes and labelling of ingredients that affect the classification of the product;
  3. introduction of fold-out labels as a standard solution, not only for small products;
  4. introduction of requirements for refill stations;
  5. update requirements for label appearance and sizes
  6. determining the exact time to update chemical product labels;
  7. introduction of digital product labeling;
  8. introduction of the definition of a multi-constituent substance MOCS;
  9. introduction of new obligations for distributors in connection with the notification of hazardous mixtures in PCNs;
  10. other changes.

More information on the new CLP criteria: https://ekotox.eu/