Compliance Deadlines: Key Transition Timelines Under the CLP Regulation
- CLP Regulation Article 61.
There are various transition dates for provisions, including but not limited to:
- New timescales on updating labels after a classification change and new advertising rules apply from 20 May 2026;
- New label formatting rules for new products placed on the market apply from 20 November 2026, but black text on a white background applies from 20 May 2026; and
- There are different timelines and transitional deadlines for existing substances and mixtures.
Comment
The key provisions are just some of the significant changes to the EU chemicals regime that the new CLP Regulation will introduce, but they do mean additional obligations and have cost implications across the industry.
Companies will need to classify and label chemicals according to new hazard classes and new specific labelling requirements (detailed above) – this will impact chemical manufacturers but also downstream users where products contain the relevant hazard classes. The introduction of digital labelling is intended to streamline the updates, however mandatory elements must still be present on the physical label.
There is a specific focus on increased compliance for online sales, ensuring that hazards are clearly communicated via online marketplaces (such as hazardous information display and design requirements for the online store). This may introduce obligations on online companies where previously they had not been obligated.
We recommend a full review of the changes, and preparatory work to update labelling and develop compliant packaging where applicable.
It is not clear at this point if the updated CLP Regulation will be replicated in Great Britain. There is currently sustained opposition, including from industry.
Manufacturers, importers, and downstream users must classify their products by the regulation and provide appropriate labels and packaging based on the classification, especially for hazardous chemicals, thereby ensuring the protection of human health and environmental safety.
Additionally, the regulation incorporates the UN Global Harmonized System (GHS) for chemical classification and labelling into EU law, fostering global consistency in the communication of chemical hazards.
According to the regulation, CLP regulation labels should be securely attached to one or more surfaces of the packaging and be readable, containing essential elements such as:
● Supplier name, address, and contact information
● The nominal quantity of substances or mixtures in the packaging
● Product identifier
● Hazard pictograms
● Signal words
● Hazard statements
● Appropriate precautionary statements
● Additional information
With advancements in technology and increasing safety demands, the EU revised the regulation in April 2024, focusing on improving the clarity, transparency, and readability of labels, making it easier for consumers and professionals to understand the potential hazards of chemicals.
The key goals of these revisions include:
● Enhancing the readability and recognizability of chemical labels to ensure users can quickly identify hazards
● Increasing the transparency of hazardous information to help users better understand the risks associated with chemicals
● Strengthening protections for specific groups, such as household users, industrial workers, and emergency responders, to ensure proper safety during chemical handling.
OJL202402865ENTXT 1.pdf concerning labelling requirements:
General Requirements for Labelling