The CLP Regulation is entering a crucial phase: between 2026 and 2027, several deadlines will come into force with a direct impact on the classification, labelling and management of Safety Data Sheets (SDS) for chemical substances and mixtures.
With the entry into force of new ATPs, new hazard classes and the “New CLP”, companies operating in the chemical sector will be required to adapt processes, labels and documentation within very tight timelines. In this article, we clarify key dates, obligations and operational implications, helping you prepare in advance and avoid the risk of non-compliance.
| Deadline | Regulation | Topic |
| 1 May 2026 | 22nd ATP | Harmonised classification |
| Regulation (EU) 2023/707 | Applies to new mixtures placed on the market | |
| 1 July 2026 | Regulation (EU) 2024/2865 | Fold-out and digital labels EU supplier on the label |
| 1 November 2026 | Regulation (EU) 2023/707 | Applies to all substances present on the market |
| 1 January 2027 | Regulation (EU) 2024/2865 | New product identifiers for mixtures |
| 1 February 2027 | 23rd ATP | Harmonised classification |
22nd and 23rd ATP: what changes in harmonised classification
22nd ATP – Mandatory from 1 May 2026
The 22nd ATP (Reg. (EU) 2024/2564) introduces significant changes to Annex VI of the CLP Regulation:
- 16 substances with amended harmonised classification
(e.g. formaldehyde, n-hexane, formic acid, peracetic acid) - 27 new substances with harmonised classification
(e.g. silver powder, nano-silver) - 7 substances removed from Annex VI
23rd ATP – Mandatory from 1 February 2027
The 23rd ATP provides for:
- 22 new substances added to Annex VI
(e.g. nitrous oxide, Pigment Red 53:1) - 10 amended harmonised classifications
(e.g. IPBC, isophorone diisocyanate, 2-phenylpropene) - No substances removed
Both the 22nd and 23rd ATPs become mandatory for all European suppliers from their respective application dates. However, voluntary early adoption of the new harmonised classifications is already possible.
Regulation (EU) 2023/707: new CLP hazard classes
Regulation (EU) 2023/707 introduces new hazard classes not foreseen by the GHS, with a significant impact on SDS, labels and risk assessment:
- Endocrine disruptors (human health and environment)
- PBT / vPvB
- PMT / vPvM
Which products are affected?
- New mixtures placed on the market after 1 May 2026
→ For mixtures already on the market before this date, a transitional period applies until 1 May 2028 - All substances, regardless of the placing-on-the-market date
→ From 1 November 2026, they must be classified and labelled, where applicable, with the new EUH statements
Regulation (EU) 2024/2865: the “New CLP”
From 1 July 2026, Regulation (EU) 2024/2865 introduces provisions on fold-out and digital labels, as well as on the European supplier, bringing significant operational and digital changes.
From 1 July 2026:
- Fold-out labels
- Digital labels
- Indication of the European supplier on the label
From 1 January 2027:
- New product identifiers for mixtures
→ Update of the “Contains” section on labels to include:
- endocrine disruptors
- PBT / vPvB
- PMT / vPvM
What will be the practical impacts of CLP 2026 for chemical companies?
These deadlines will require:
- review of CLP classifications
- large-scale SDS updates
- adaptation of physical and digital labels
- the need for reliable software tools for regulatory management
Using up-to-date and automated SDS management software, such as EPY X, becomes essential to manage the transition efficiently, reduce errors and minimise the risk of non-compliance and penalties.
Would you like to explore CLP 2026 in more detail?
👉 Join our dedicated webinar on the new CLP hazard classes and regulatory transition management
🔗 https://webinar.epy.it/product/nuove-classi-di-pericolo-clp-impatti-regolatori-sulle-miscele-e-gestione-della-transizione/
