Updated EU Chemicals, Labelling and Packaging (CLP) Regulation: implications for labels, advertisers, online marketplaces

The updated EU Classification, Labelling and Packaging of hazardous chemicals Regulation (CLP Regulation) was published in the Official Journal of the EU on 20 November 2024 and enters into force on 10 December 2024.

New provisions and clarifications include:

• practical labelling changes, in particular mandatory formatting rules for labels to ensure legibility (including minimum font sizes and spacing), greater flexibility to use fold-out labels/leaflets (with mandatory content and arrangement of label elements), additions to what must be included when using ‘limited’ labelling, and voluntary digital labelling;
• mandatory EU-based supplier, along with contact information;
• new requirements for adverts to include fundamental hazard information (including pictograms and signal words) and for distance sales including via online marketplaces to carry full CLP label elements;
• introduction of specific rules (and in some cases prohibitions) for refills and refill stations; and
• new hazard classes, new rules around endocrine disruptors, classification change label updates, and changes to harmonised classifications and the way they are notified.

The updated CLP Regulation will have significant implications for a wide range of businesses, including manufacturers, downstream users, retailers and distributors, and especially for non-EU based sellers and online marketplaces.

These changes will apply from as early as 20 May 2026, although there are various transitional compliance deadlines and different timeframes for new and existing products (detailed further below).

Background

The CLP revision is part of the European Green Deal for the strengthening and simplification of the legal framework for chemicals to ensure a toxic-free environment. The updated regulation is a key pillar of EU chemicals legislation and aims to better identify and classify hazardous chemicals, improve communication on chemical hazards and address legal gaps and high levels of non-compliance.

Key provisions

Among many other changes, the following key updates have been made:

• Mandatory formatting rules for labels: Formatting rules for labels now include (but are not limited to): minimum font sizes, text must be black on a white background, and the distance between two lines must be at least 120% of the font size. This is likely to have the practical impact of larger labels being required on packaging (although the greater flexibility to use fold-out labels is a welcome change that may somewhat mitigate this impact).
• EU supplier: Sellers based outside the EU will be required to have an EU supplier, and the EU supplier contact details must be included on the label. This is to improve compliance and enforcement with the CLP Regulation and to avoid the consumer becoming the technical legal importer when buying a substance or mixture via distance sales from economic operators established outside the EU.
• Advertising: All adverts for hazardous substances or mixtures must include pictograms, H-Statements and EUH-Statements. Any advert for hazardous substances or mixtures sold to the public must also include the statement "Always read and follow the information on the label”. Further, for any substance or mixture sold via online sales, the offer must clearly and visibly show the label elements.
• Refills and refill stations: Specific rules for labelling and packaging of substances and mixtures supplied to the general public and professional users via refill stations have been introduced to take account of the increasing trend of selling certain chemicals, such as detergents, without packaging in order to reduce waste and to facilitate more sustainable sales forms. The new rules set out specific conditions for such types of sales including the requirement for refill stations to carry labels corresponding to the labels for each hazardous substance or mixture supplied at the station and to implement risk mitigation measures to ensure that refilling can be performed safely, for example by preventing overfilling, contamination and especially any uncontrolled operation of the refill station by children, as well as avoiding any reaction between substances or mixtures dispensed through the refill station, or between those substances or mixtures, and any residues in the packaging to be refilled. The new rules also establish a list of hazard classes and categories for certain substances or mixtures that are prohibited to be sold via refill stations.
• Updating information on labels: If the classification becomes more severe, or new supplemental information is added to the label, the supplier must update the labels without undue delay (and no later than 6 months). For any other change to classification or label, the label must be updated without undue delay (and no later than 18 months);
• New hazard classes for endocrine disruptors and other harmful chemicals: New hazard classes for endocrine disruptors, as well as for chemicals that do not break down in the environment and can accumulate in living organisms. Some of these hazard classes are already partially covered in other legislation (for example, endocrine disruptors are partially covered by EU REACH and Biocidal Products Regulation) whereas others are new in EU legislation. The introduction of these additional hazard classes means a significant proportion of chemicals will come under new regulatory scrutiny, and more organisations in the supply chain will have to carry out extended regulatory assessments; and
• Harmonised classification and labelling (CLH): CLH has been updated to include not just groups of substances, but to prioritise groups of substances over individual substance proposals. The Commission can also request proposals (rather than waiting for a competent agency to trigger them) and has a new self-imposed deadline to adopt CLH proposals (without undue delay and before the end of the calendar year following publication of the RAC opinion).

Compliance deadlines (transitional)

There are various transition dates for provisions, including but not limited to:

• New timescales on updating labels after a classification change and new advertising rules apply from 20 May 2026;
• New label formatting rules for new products placed on the market apply from 20 November 2026, but black text on a white background applies from 20 May 2026; and
• There are different timelines and transitional deadlines for existing substances and mixtures.

Comment

The key provisions are just some of the significant changes to the EU chemicals regime that the new CLP Regulation will introduce, but they do mean additional obligations and have cost implications across the industry.

Companies will need to classify and label chemicals according to new hazard classes and new specific labelling requirements (detailed above) – this will impact chemical manufacturers but also downstream users where products contain the relevant hazard classes. The introduction of digital labelling is intended to streamline the updates, however mandatory elements must still be present on the physical label.

There is a specific focus on increased compliance for online sales, ensuring that hazards are clearly communicated via online marketplaces (such as hazardous information display and design requirements for the online store). This may introduce obligations on online companies where previously they had not been obligated.

We recommend a full review of the changes, and preparatory work to update labelling and develop compliant packaging where applicable.

It is not clear at this point if the updated CLP Regulation will be replicated in Great Britain. There is currently sustained opposition, including from industry.