The deadlines for the mandatory application of changes to the CLP Regulation resulting from ATP 22 (1 May 2026) and ATP 23 (1 February 2027) are approaching, requiring urgent action from chemical companies. Companies should analyse as soon as possible the impact of the new classifications on their products and update documentation, labels and regulatory notifications.
Companies operating in the chemical sector in the EU are entering a decisive phase of preparations for the implementation of the latest changes to the CLP Regulation. The 22nd and 23rd ATP amendments introduce a broad range of new and updated substance classifications that directly affect the compliance of products, documentation and labels.
Key dates
1 May 2026 – mandatory application of ATP 22
1 February 2027 – mandatory application of ATP 23
Although the first deadline has already passed, many companies are still in the process of implementing the changes or have not completed key updates. This means a real risk of regulatory non-compliance.
What is changing?
The delegated regulations published by the European Commission: (EU) 2024/2564 and 2025/1222 introduce new and updated classifications for chemical substances, including CMR substances. The updates cover broad groups of substances used in many industries.
What does this mean for companies?
In practice, the new provisions require comprehensive action. Organisations should urgently:
• conduct a review of their product and substance portfolio,
• assess the impact of the new classifications on chemical mixtures,
• update Safety Data Sheets (SDS),
• revise product labels and markings,
• verify and update PCN notifications (UFI),
• adapt REACH documentation,
• take into account changes relating to occupational health and safety and transport,
• ensure appropriate communication throughout the supply chain.
Last chance for compliance with ATP 22
The deadline of 1 May 2026 has already passed, which means that all ATP 22 requirements should be implemented, products placed on the market must be fully compliant, and failure to adapt may result in regulatory and operational risks.
At the same time, companies should already be actively preparing for the next stage of changes resulting from ATP 23.
Companies that act proactively reduce the risk of non-compliance, costly corrections and disruptions to business operations.
Source: https://eur-lex.europa.eu/legal-content/PL/TXT/PDF/?uri=OJ:L_202402564
Source: https://eur-lex.europa.eu/legal-content/PL/TXT/PDF/?uri=OJ:L_202501222