The European Commission has proposed a package of simplifications for the revision of the CLP Regulation published in 2024. Below we present a summary and dates of entry into force of potential simplifications of the regulations.
In November 2024, Regulation (EU) 2024/2865 of the European Parliament and of the Council amending Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures, the so-called revision of the CLP Regulation, was published. The new regulation assumes for example: new classification rules, new labelling requirements, new regulations on advertising and distance sales or requirements for refilling stations. Most of the changes come into force from 1 July 2026.
After the content of revised CLP was published, the industry pointed out many difficulties to implement some of the new rules. The main problem was the use of the right format with a limited size of the label or packaging, which was also associated with more expensive labels and generating more waste. It also pointed out the difficulties in including all information about the danger in marketing materials and the possible overwhelming of the consumer with the amount of information.
Therefore in the mid of 2025, the European Commission organized a meeting on simplification of CLP regulations, the purpose of which would be to reduce the burden on companies. The talks concluded with the publication of proposals for simplifications regarding the CLP Regulation, which include:
- digitization of information through the introduction of digital contact
- labelling claims – withdrawal of minimum font size and formatting rules, leaving the obligation to update the label “without any delay”, simplification for small packages
- product advertisement must include the phrase: “‘Always read the label and product information before use’, instead of full information about the risks of CLP
- extension of transitional periods
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2024/2865 as regards dates of application and transitional provisions
Changes in deadlines in relation to Regulation (EU) 2024.2865 include:
- deletion of Article 1 points (14), (26), (27), and parts of Annex II from the effective date from 1 July 2026
- deletion of Article 1 point (15c), Annex II point (2),(3) from the effective date from 1 January 2027
- addition of a third transitional period falling on 1 January 2028 and transfer of obligations under the above-deleted articles
- addition of a transition period to sell out of stock for products with the “old label”
The proposal amends Article 2 of the Regulation (EU) 2024/2865 that sets the dates of entry into force and entry into application of the provisions of that Regulation:
| Deadline number | Date of application | Part of the Regulation | Content |
| 1 | 1 July 2026 [*until 30 June 2026 products may be place on the marked based on the “old CLP rules”] | Article 1, point (3)(b) | Supplier must be established in the EU, which shall be identified on the label and fulfil the requirements |
| Article 1, points (4) to (7) | Evaluation of a substance containing more than one constituent | ||
| Article 1, point (12)(a) | Supplemental information on the label can be use; other than that referred to in paragraphs 1, 2 and 6 to 9 | ||
| Article 1, point (13) | Labelling for small packaging: the label elements shall be provided in accordance with section 1.5.1 of Annex I | ||
| Article 1, points (15)(a) and (b) | Labels shall be firmly affixed, readable horizontally when the package is set down normally. Fold-out label shall be presented in accordance with section 1.2.1.6 of Annex I. For digital label a data carrier linking to that digital label shall be firmly affixed on the physical label or packaging. The data carrier shall be accompanied by the statement “More hazard information available online”. | ||
| Article 1, points (17), (18), (22) and (23), | Physical and digital labelling corelation Refill stations are allowed only when certain conditions from Annex II are fulfilled Obligation to notify the Agency The classification and labelling inventory | ||
| points (4), (8), (10) and (11) of Annex I | Fold-out labels – elements Elements for small packaging labelling Elements for packaging less than 10ml Label elements that may be provided on a digital label only | ||
| point (1) of Annex II | Supply via refill stations | ||
| 2 | 1 January 2027 [*until 31 December 2026 products may be place on the marked based on the “old CLP rules”, unless they fall within the scope of the amendments in force from 1 July 2026] | Article 1, points (1) and (9), | Providing an obligation for downstream users, importers and distributors to submit information in PCN |
| Article 1, points (24)(b) and (d) | Poison Center Notification by distributor which rebrand or relabel the hazardous mixture | ||
| Annex IV | PCN Notification – new obligation for importers, downstream users and distributors | ||
| 3 | 1 January 2028 [*until 31 December 2027 products may be place on the marked based on the “old CLP rules”, unless they fall within the scope of the amendments in force from 1 July 2026 or 1 January 2027] | Article 1, points (14), (15)(c), (26) and (27), | Time for updating information on labels Format in accordance with Annex I Advertisement of substance or mixture classified as hazardous Distance sales offers and labelling elements |
| points (2) and (3) of Annex I | Minimum dimensions of labels and pictograms and minimum font size The text on the label characteristic (colour, distance, font, space) | ||
| point (2) of Annex II | Ready mixed cement and concrete label elements Substance and mixture labelling supplied at a filling stations and pump |
Transition periods for stock-out:
Substances and mixtures that were placed on the market after the entry into force of the regulation can remain on the market with the “old” label for up to 35 months from the date of entry into force of the Omnibus.
Effective dates of additional provisions:
Provisions introducing “digital contact” – 36 months from the entry into force of the Omnibus.
Omnibus Chemicals Simplicity Package: https://ekotox.eu/news/omnibus-chemicals-simplicity-package/
Amendments to the annexes to the Cosmetics Regulation: https://ekotox.eu/news/amendments-to-the-annexes-to-the-cosmetics-regulation/