Premise
On 16 May 2025, the European Commission held an online meeting with more than 570 participants from various sectors to gather input on the revision of the CLP Regulation and to discuss potential simplifications following the adoption of Regulation (EU) 2024/2865.
Following this meeting, it was decided that enhancing the practicality of CLP for businesses required both extending some application deadlines and streamlining certain labelling requirements. The summary below presents the European Commission’s proposals along with concise remarks.
The European Commission’s proposals, in practice.
- Elimination of the maximum limit of 6 months to update the label in the event of a worse classification.
- While this may be beneficial for lengthy supply chains, a precise and more realistic limit would provide more clarity, as the phrase “without undue delay” is open to interpretation.
- For mixtures placed on the market before 1 January 2027, a transitional period until 1 January 2029 is proposed to update the product identifier on the label.
- This transitional period could allow companies, already struggling with reclassifications due to the inclusion of the new hazard classes, to limit the need for label revision.
- Proposal to delaythe application date to1 January 2028 for: updating the information in the label, advertisement and distance sales offers.
- Unfortunately , multiple label update deadlines do not prevent obligations from being applied in an orderly manner.
- U-turn on the provisions relating to the graphic requirements of the label introduced with Regulation 2024/2865: no more white background, minimum font size and line spacing, and elimination of the new requirements introduced for packaging < 3l.
- While Regulation 2024/2865 may present significant challenges for companies, a complete reversal at this stage could undermine efforts to ensure the safety of both workers and consumers.
- Proposed to no longer require the UFI code among the label elements in filling pumps.
- In fact, the UFI code of fuels that meet precise technical requirements does not seem to be a priority for health protection.
- The derogation for containers≤ 10ml now clarifies that label elements may be omitted if the product is not hazardous for the human health (except for irritants) and does not include EUH208.
- This measure is not a simplification, but rather a clarification, adding a labelling obligation for very small packages in cases where there is a risk of allergic reaction for individuals already sensitised to certain allergens present in the mixture.
- It is proposed to report information relating to additional suppliers (address, contact, etc.) only on the digital label, as long as the main supplier’s labels are on the physical label.
- A simplification that has its own reason in terms of space on the label, while safeguarding the availability of information.
Lastly, the European Commission has proposed introducing a definition for “Digital Contact” in CLP as part of broader efforts to digitize supply chain operations. This initiative is intended to establish a communication channel that facilitates efficient information exchange among supply chain participants and consumers. If adopted, the digital contact would be required to appear on product labels.
Please note, your labels are still subject to review as this is only a proposal that must go through the standard evaluation process.
What would remain of Regulation 2024/2865?
For those who are wondering what would remain of the “New CLP”, (if the proposal is approved) we remind you that this regulation introduces – and maintains – important provisions, including:
- The regulation of charging stations and bulk products, which are increasingly in use.
- The labelling provisions in the case of advertisement and distance sales offers.
- The standardization of fold-out labels (and no longer usable only in special packaging circumstances).
- The obligation to indicate a European supplier for hazardous chemicals imported from non-EU countries.
