Updated CLP Regulation - which deadlines and obligations you should keep in mind

The revised CLP Regulation (Classification, Labeling and Packaging) means new requirements for companies: for example with regard to classification and labeling, C&L and PCN notifications and online product advertising.

Following Delegated Regulation (EU) 2023/707, which has been in force since April 2023, and the inclusion of the four new hazard classes in the CLP Regulation, Regulation (EU) 2024/2865 has also been in force since December 10, 2024 - with the main changes being online trade, labeling of substances and the new classification rules for complex substances, the so-called MOCS (“More than One Constituent Substances”). We summarize the most important obligations arising from the revised CLP Regulation for you.

New hazard classes

Regulation (EU) 2023/707 introduces the new hazard classes for endocrine disruptors (ED HH and ED ENV), persistent, bioaccumulative and toxic products (PBT and vPvB) and persistent, mobile and toxic products (PMT and vPvM). Are there substances and mixtures in your portfolio that need to be reclassified? If so, you must update safety data sheets (SDS), labeling and, in the case of online sales, the hazard statements on the Internet. The classification and labeling regulations already apply to substances that have been placed on the market since May of this year. Please note the following additional deadlines for the implementation of the classification and labeling regulations:

May 1, 2025: for substances placed on the market since May 1, 2026
May 1, 2026: for mixtures placed on the market from May 1, 2026.
Nov. 1, 2026: for substances already placed on the market before May 1, 2025
May 1, 2028: for mixtures already placed on the market before May 1, 2026.

Label design

As a general rule, labels must be legible. Depending on the size of the packaging, minimum font and line spacing sizes are prescribed (Annex I, section 1.2.1.4. Table 1.3). Only one font is permitted and the background of the label must be white. As the task is logistically and technically complex, you should deal with the requirements at an early stage in order to implement them on time by January 1, 2027.

C&L declarations

Regulation (EU) 2024/2865, Article 40, requires additional information for C&L declarations. These requirements will apply from July 1, 2026. Among other things, manufacturers and importers will be obliged to determine and report ATE values (Acute Toxicity Estimates, ATE) for all substances classified as acutely toxic - regardless of the hazard category. They must also give reasons if they classify a substance differently.

Advertising and online trade

Even before the revision, certain information on the hazardous properties had to be provided in advertisements for hazardous substances. This mandatory information has now been extended. In addition, the complete labeling of a product in accordance with CLP must be clearly indicated in online stores. These extended information obligations in advertising and distance selling offers will apply from July 1, 2026 - both in the B2C and B2B sectors.

PCN notifications by retailers

The revision now clarifies that retailers, as part of the supply chain, must ensure that PCNs are available for the products concerned. This applies to all EU countries to which they wish to deliver. If the notifications for a country have not already been carried out by the supplier, for example, the retailer must carry out this notification themselves.

Current developments

The revision of the CLP Regulation is now in force and the transitional periods for implementation are running. At the same time, however, discussions are now being held at EU level to revoke certain new regulations (particularly with regard to labeling), as the burden on industry was apparently significantly underestimated. More detailed information is expected in the coming weeks. We will keep you up to date via the KFT newsletter and the regular free webinar KFT Chemical Compliance Live. Register for both via the KFT homepage .

Who we are

KFT Chemieservice GmbH, a member of the Infraserv Höchst Group, is one of Germany's leading chemical compliance service providers. Our services ensure that companies comply with all the requirements of chemicals legislation without exception.

What we do for you

We analyze the status quo and plan the necessary steps together with you.
We advise you on the correct implementation of the labeling requirements.
We support you in implementing the amended C&L notifications, new requirements for advertising and online stores and all other new requirements.
We check and update your safety data sheets (SDS) and can also take over the complete SDS management on request.