By Anna Caldiroli
Let’s talk about deadlines
The Delegated Regulation (EU) 2023/707 – published in the Official Journal on March 31, 2023 – amends the CLP Regulation regarding the criteria and hazard classes for the classification, labeling, and packaging of substances and mixtures.
The significant modifications introduced are due to the necessity of adapting the CLP Regulation to technological and scientific advancements, introducing new criteria and hazard classes.
As a result, new hazard classes and categories have been introduced, including:
| Hazard Class and Category Code | Hazard Statement Code | Hazard Statement |
| ED HH 1 | EUH380 | May interfere with the endocrine system in humans |
| ED HH 2 | EUH381 | Suspected of interfering with the endocrine system in humans |
| ED ENV 1 | EUH430 | May interfere with the endocrine system in the environment |
| ED ENV 2 | EUH431 | Suspected of interfering with the endocrine system in the environment |
| PBT | EUH440 | Accumulates in the environment and living organisms, including humans |
| vPvB | EUH441 | Highly accumulates in the environment and living organisms, including humans |
| PMT | EUH450 | May cause persistent and widespread contamination of water resources |
| vPvM | EUH451 | May cause very persistent and widespread contamination of water resources |
Our Clients Ask Us If…
- Substances placed on the market before May 1, 2025, and still available after November 1, 2026, must be relabeled?
By November 1, 2026, substances placed on the market before May 1, 2025, and still available to any downstream supplier in the supply chain must be relabeled in compliance with the CLP Regulation, to include the new hazard classes introduced with Regulation (EU) 2023/707. - Mixtures placed on the market before May 1, 2026, and still available after May 1, 2028, must be relabeled?
By May 1, 2028, mixtures placed on the market before May 1, 2026, but still present on the shelves of any supplier in the supply chain must be relabeled in compliance with the CLP Regulation, to include the new hazard classes introduced with Regulation (EU) 2023/707.
It is understood that relabeling is necessary if the product, upon reassessment of its classification, is found to fall under one of the new hazard classes and categories introduced by the Delegated Regulation (EU) 2023/707.
IMPORTANT: ECHA Clarification
ECHA has specified that:
- “Substances placed on the market before May 1, 2025”, and
- “Mixtures placed on the market before May 1, 2026”
refer to batches of products actually placed on the market before the specified date. New quantities of a product, even if they were already part of a company’s portfolio before the indicated dates for substances and mixtures, must be considered as new market entries and therefore cannot benefit from the transitional period.
How do we support EPY users?
We are available with:
- “Training hour packages” that users can purchase based on their specific needs for further learning.
- Multiple webinars, available on-demand or live, with the opportunity to submit specific questions to the speaker.
