The CLP revisions introduce new hazard classes (including ED, PBT/vPvB and PMT/vPvM) as well as significant changes to the rules for the classification and labelling of substances and mixtures, substantially expanding the obligations of chemical industry companies. The key implementation deadlines cover the period 2025–2028, with particularly urgent changes – such as the new classification rules for MOCS and the possibility of using digital labels – becoming applicable as early as 1 July 2026.
The EU legislation governing the classification, labelling and packaging of chemicals (CLP) is currently undergoing one of the most significant reforms in recent years. The introduction of new hazard classes and the changes resulting from Regulation (EU) 2024/2865 require companies to urgently adapt their documentation, labels and approach to the classification of substances and mixtures. The coming months – particularly the second half of 2026 – bring key deadlines, failure to meet which may result in regulatory non-compliance.
New CLP hazard classes – a significant change in the approach to risk assessment
Regulation (EU) 2023/707 introduces three new hazard classes that were not previously included in the GHS system. These are:
• Endocrine disruptors (ED) – for human health and the environment,
• PBT / vPvB – persistent, bioaccumulative and toxic substances and very persistent and very bioaccumulative substances,
• PMT / vPvM – persistent, mobile and toxic substances and very persistent and very mobile substances.
The introduction of these classes significantly expands the scope of hazard assessment and requires companies to conduct a more detailed analysis of product composition and available toxicological and environmental data.
The implementation of the new CLP requirements is taking place in stages; however, some deadlines have already passed or are currently approaching. This means that in 2026 companies are in a critical transitional phase – particularly with regard to existing substances, which must soon be fully aligned with the new hazard classes.
Deadlines:
• 1 May 2025 – obligation applies to new substances,
• 1 May 2026 – obligation applies to new mixtures placed on the market,
• 1 November 2026 – final deadline for existing substances,
• 1 May 2028 – final deadline for existing mixtures
Updated CLP Regulation – new obligations for labelling and communication
Regulation (EU) 2024/2865 introduced additional changes that will become applicable on 1 July 2026. The most important include:
• the possibility of using fold-out labels,
• the introduction of digital labels (e.g. via QR codes),
• mandatory indication of an EU supplier on the label
Further stages of the changes include:
• 1 January 2027 – expanded mixture identifiers (including the obligation to indicate ED, PBT/vPvB and PMT/vPvM substances),
• 1 January 2028 – new label formatting requirements, requirements for advertising and online sales, and fuel labelling.
These changes significantly affect the way hazards are communicated and require adaptation of both physical labels and digital information.
New MOCS classification rules
One of the most groundbreaking changes is the introduction of new classification rules for MOCS (More Than One Constituent Substances). From 1 July 2026, the principle applies that such substances must be classified analogously to mixtures – using calculation methods and a “worst-case approach”.
MOCS include, among others:
• multi-constituent substances,
• UVCBs (substances of unknown or variable composition),
• mono-constituent substances containing significant impurities or additives.
In practice, this means more stringent classification outcomes, the need for full knowledge of the chemical composition, and the re-evaluation of existing safety data sheets and C&L notifications.
Ekotox website: https://ekotox.eu/clp-regulation/
