CLP Deadlines July 2026: what changes for manufacturers, importers and distributors of chemical products

Starting from 1 July 2026, a series of important amendments to the CLP Regulation will enter into force.
In this brief article, we summarise the CLP obligations that will directly impact companies that manufacture, import or distribute chemical substances and mixtures on the European market.
This article does not include those obligations which, although originally having an application date of 1 July 2026, have been postponed to 1 January 2028 by the Stop the Clock Regulation.
The main changes will primarily affect labelling and classification, as summarised below:

The updates mainly concern CLP labelling, the introduction of the digital label, the new classification criteria for multi-constituent substances and the management of specific concentration limits, M-factors and Acute Toxicity Estimates (ATEs).
For companies operating in the chemical sector, these changes represent a further step towards an increasingly structured management of regulatory compliance.

Key CLP changes applicable from 1 July 2026

• The amendments introduced will affect several aspects of the regulatory management of chemical products:
• New requirements for supplier identification on labels
• Extended use of fold-out labels
• Introduction of the digital label
• New exemptions for small packages
• Specific requirements for cement, ammunition and refill stations
• Updated classification rules for multi-constituent substances and mixtures
• New criteria for concentration limits, M-factors and ATEs

European supplier mandatory on labels

From July 2026, the entity identified as the supplier on the label must be established within the European Union.
Non-European suppliers are not accepted.
This change particularly affects importers and distributors placing products originating from third countries on the market and will require a prior review of labels currently in use.

Fold-out labels: greater flexibility for manufacturers

One of the most significant changes concerns fold-out labels.
From 1 July 2026, fold-out labels become a standard format that may always be used and are no longer limited to packages that are difficult to label.
The first front page of the label must nevertheless contain all essential elements required by the CLP Regulation.

CLP digital label: what can be included

The digital label represents one of the most anticipated innovations in the sector.
The digital label complements the physical label and is accessible through a data carrier, free of charge and within a maximum of two clicks. It is important to underline that the digital label does not replace the physical label, which remains mandatory on the packaging.
Information that may be included on the digital label
The digital label may contain exclusively supplementary NON-mandatory elements, such as:

• Additional translations
• Instructions for use
• Sustainability information
• Supporting informational content

Elements required by other EU Regulations (e.g. VOC content, compliance symbol under the Aerosol Dispensers Directive) are considered mandatory and must appear on the physical label.

Labelling exemptions for packages < 10 ml

Labelling elements for products packaged in containers up to a maximum of 10 ml are exempt from CLP labelling provided that they are intended for research and development or quality control purposes.The exemption applies only if the product does not require EUH statements listed in Annex II Parts 1 and 2 of CLP and is not classified as hazardous to health, with the exception of Skin and/or Eye Irritation Category 2.

New requirements for the labelling of cement, ammunition and refill stations

Labelling of cement and lime sold in bulk
Ready-mixed cement and lime mixtures sold in bulkmust be accompanied by a copy of the label.

Labelling of military ammunition
CLP labelling does not apply to military ammunition when it could compromise its functioning or operational camouflage. In such cases, an SDS or a copy of the mandatory label elements must be provided.

Labelling for refill stations
Refill stations must always display the CLP label relating to the bulk product.
Products classified as hazardous to health cannot be supplied through refill systems, except for products classified as Skin and/or Eye Irritant Category 2.

New classification rules for multi-constituent substances and mixtures

The amendments introduced by CLP also affect the assessment methods for substances containing more than one constituent and for mixtures.

A substance containing more than one constituent, in the form of a single constituent, an identified impurity or an additive for which experimental or epidemiological information is available, shall be assessed using the available information on the known constituents and on the substance itself.

For the assessment of CMR, EDHH, EDENV, hazardous to the aquatic environment, PBT, vPvP, PMT and vPvM multi-constituent substances, the available information for each known constituent shall be used.

Available information on the multi-constituent substance itself shall be taken into account if one of the following conditions is met:

a) the information demonstrates CMR, EDHH, EDENV, persistence, mobility and bioaccumulation properties or an absence of degradation;

b) the information corroborates the conclusions based on the available information on the constituents of the substance.

The above does not apply to multi-constituent substances extracted from plants or plant parts that have not been chemically modified.

For the assessment of CMR, EDHH, EDENV, hazardous to the aquatic environment, PBT, vPvB, PMT and vPvM mixtures, only the information available for the substances contained in the mixture shall be used and not the information available for the mixture itself.

Concentration limits, M-factors and ATEs

For non-harmonised substances, manufacturers, importers and downstream users establish specific concentration limits (where lower than generic limits), M-factors for substances hazardous to the aquatic environment Acute and Chronic Category 1, and Acute Toxicity Estimates (ATEs).

Specific limits always take precedence over generic limits and apply to the concentration of the identified impurity, additive or constituent responsible for the classification, including in mixtures of mixtures.

How to prepare for the CLP 2026 deadlines

The changes introduced by the CLP Regulation confirm an already established trend: chemical compliance management requires increasingly advanced tools capable of automating classification, labelling and Safety Data Sheet generation. Companies managing hundreds or thousands of formulations must rely on systems capable of:

• Automatically updating regulatory criteria
• Managing multilingual labels
• Generating compliant SDSs
• Correctly applying classifications and specific limits
• Reducing the risk of manual errors

SDS and CLP software: a strategic ally for compliance

Specialised SDS and CLP management software enables companies to efficiently address continuous regulatory updates while reducing operational time and non-compliance risks.

Would you like to verify whether your processes are ready for the CLP 2026 deadlines?

Request a free demo of EPY X and discover how to automate SDS management, CLP classification, labelling and international regulatory compliance.