CLP Regulation – Obligations, deadlines and how to maintain the marketability of your products

The CLP Regulation (Classification, Labeling and Packaging) covers the classification, labeling and packaging of chemical substances and mixtures in the EU. Companies should keep an eye on the associated compliance requirements.

Every further amendment to the CLP Regulation means new labeling obligations for substances and mixtures as well as additional communication and documentation obligations in the supply chain for the companies concerned. We highlight the most important current developments and tell you what is important now.

New hazard classes with consequences

Delegated Regulation (EU) 2023/707 introduced new hazard classes into the CLP Regulation - 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). It is now important to quickly check which substances and mixtures in your portfolio need to be reclassified. In the event of a reclassification, you must update safety data sheets (SDS), labeling and, in the case of online sales, the hazard information on the Internet.

The regulation provides for the following transitional periods for the implementation of the classification and labeling regulations:

• May 1, 2025: for substances placed on the market from May 1, 2025.
• 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.

Product notification according to Article 45 CLP Regulation

According to the CLP Regulation, Annex VIII (German Only) , manufacturers, importers and/or distributors are obliged to notify hazardous mixtures. You should therefore check whether you need to update your product notification as a result of the reclassification.

21st ATP to the CLP Regulation applies

With Delegated Regulation (EU) 2024/197, the EU Commission has updated Annex VI of the CLP Regulation. This 21st ATP (Adaptation to Technical Progress) came into force on January 25, 2024.

For you as a supplier, the deadline is 1 September 2025, by which date you must have adapted the labeling and packaging of the substances and mixtures concerned to the new or amended classification.

Outlook

The updated CLP Regulation is expected to be adopted in the second quarter of 2024. This will entail far-reaching changes to labeling requirements, C&L notifications, requirements for advertising and online stores.

Who we are

KFT Chemieservice GmbH, an Infraserv Höchst Group company, is one of Germany’s leading chemical compliance service providers. We ensure that companies comply fully with all the requirements imposed by chemical laws.

What we do for you

• We analyze the status quo and plan the necessary steps together with you.
• We review and update your SDS and, if you wish, we can also take over the complete SDS management.
• We advise you on the correct implementation of labeling requirements.
• We support you with product notifications in accordance with Article 45 of the CLP Regulation.

The best thing to do is to contact us right away.