▪︎ CLP
CLP Revision: New requirements have been mandatory since July 1, 2026
The first transition period for the CLP Revision expired on July 1, 2026. Since then, numerous new requirements have applied to companies that place substances and mixtures on the market in the EU. These requirements pertain, among other things, to labeling, reporting obligations, responsibilities within the supply chain, and sales via digital trading platforms. Companies should therefore verify whether their classifications, labeling, reports, and distribution processes comply with the current regulations.
Increased Responsibilities for Suppliers and New Requirements for C&L Notifications
One of the main objectives of the CLP Revision is to improve transparency throughout the supply chain. To this end, an EU-based supplier must now be identified for substances and mixtures placed on the EU market. This requirement explicitly also applies to products offered through distance selling channels or online marketplaces. The responsible supplier placing the product on the market must ensure compliance with all provisions of the CLP Regulation.
At the same time, the requirements for Classification and Labelling (C&L) Notifications have been expanded. Companies must provide additional information and promptly update existing notifications whenever relevant changes occur. Furthermore, since 1 July 2026, ECHA has been publishing the identity of notifying companies in the C&L Inventory, unless a justified and accepted confidentiality claim has been submitted.
Fold-Out Labels Become a Standard Option
Important changes have also been introduced in the area of labelling. Fold-out labels may now be used as a standard option and are no longer restricted to specific exceptional cases. At the same time, it has been clarified that fold-out labels must fully comply with the design and formatting requirements of the CLP regulation on the front page, the inner pages and the back page of the label.
In addition, labelling elements required under other EU legal acts must be systematically integrated into the CLP label. Moreover, the exemptions for very small packaging have been expanded. Under certain conditions, specific labelling elements may be omitted from packaging with a capacity of less than 10 ml. However, these exemptions require a careful assessment of the relevant classification.
Refill Stations and New Hazard Communication Requirements Demand Active Compliance Management
Another significant change concerns refill stations. For the first time, the CLP Revision establishes a harmonised legal framework across the European Union for the supply of certain hazardous substances and mixtures through refill systems. Strict requirements now apply with regard to labelling, risk minimisation measures, packaging and consumer information. In addition, the use of refill stations remains restricted to specific hazard classes.
ECHA Announces Increased Enforcement Activities
At the same time, the enforcement of chemicals legislation is receiving greater attention from regulatory authorities. ECHA’s Enforcement Forum has announced several Europe-wide inspection and enforcement projects for the coming years. These initiatives will focus, among other things, on the correct classification and labelling of substances and mixtures, compliance with restrictions and products marketed through online platforms. Furthermore, the newly introduced Rapid Enforcement Initiative (REI-1) is intended to enable authorities to respond more quickly to identified cases of non-compliance.
Companies should therefore review their implementation of CLP requirements not only from a legal compliance perspective but also in view of the increasing level of regulatory scrutiny. A thorough assessment of classifications, labels, Safety Data Sheets (SDS) and notification obligations can help avoid findings during inspections and any resulting enforcement actions. With our comprehensive regulatory expertise, we help companies implement CLP requirements efficiently and maintain compliance throughout the product lifecycle.
Further CLP Deadlines Already on the Horizon
The milestone of 1 July 2026 marks only the first major implementation deadline of the CLP Revision. Additional important compliance deadlines are already approaching for companies. To ensure continued compliance, businesses should review their existing processes and documentation at an early stage and implement any necessary adjustments in due time.
We can support you with regulatory consulting services and practical compliance solutions for the implementation of CLP requirements. Please contact us at sales@kft.de or use our contact form.
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