▪︎ CLP, GHS
Plans are underway to align the CLP Regulation with the latest GHS revisions
The European Commission recently submitted a draft delegated regulation to the World Trade Organization (WTO). The aim is to align the CLP Regulation with Revisions 8 through 10 of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). In addition, selected provisions from GHS Revision 11 are to be incorporated.
Technical Update of European Classification and Labeling Legislation
On August 17, 2026, the European Union submitted a draft amendment to the CLP Regulation (Classification, Labeling and Packaging) to the WTO. The objective is to align European requirements with the latest developments in the United Nations’ Globally Harmonized System (GHS), which serves as the worldwide framework for the classification and labeling of chemicals. The proposed amendments affect numerous annexes to the CLP Regulation and are intended to ensure that European chemicals legislation remains consistent with the current state of scientific and technical knowledge.
The GHS is revised on a regular basis to reflect new findings in hazard assessment, labeling, and risk communication. Consequently, European legislation must be continuously updated accordingly. The proposed amendments therefore do not constitute a fundamental policy shift, but rather a comprehensive technical update of existing requirements. Companies and other stakeholders may submit comments on the draft until October 16, 2026. Adoption of the regulation is currently envisaged for the fourth quarter of 2026.
New Requirements for Hazard Assessment and Risk Communication
A key focus of the proposed amendments is the further development of classification and assessment methodologies. Among other changes, new criteria and decision-making approaches for “chemicals under pressure” will be introduced. These measures are intended to improve the consideration of explosion hazards associated with such substances, particularly beyond the transport sector.
Furthermore, the draft regulation provides for a revision and further harmonisation of precautionary statements. The so-called P-statements are to be made clearer and more user-friendly while maintaining their practical applicability for labeling purposes. The proposal also places greater emphasis on the use of non-animal testing methods in the classification of certain health hazards. New provisions concerning the use of in vitro and ex vivo data, as well as other alternative assessment approaches, are intended to enhance the evaluation of skin corrosion and skin irritation hazards.
Additional amendments relate to the classification of metals and metal compounds regarding their long-term aquatic toxicity. The proposal also supplements guidance on dust explosion hazards, updates examples of hazard pictograms, and revises references to OECD test guidelines to reflect the latest scientific standards. These measures are expected to improve the precision of hazard communication and further strengthen consistency within the CLP framework.
Transitional Periods Provide Time for Implementation
Although GHS Revision 11 contains additional amendments, the European Commission currently intends to adopt only selected provisions relating to aerosols and skin-sensitising mixtures. Further elements may be incorporated at a later stage.
Following adoption, the delegated regulation is expected to enter into force 20 days after its publication in the Official Journal of the European Union. In general, the new requirements will become mandatory 24 months after entry into force. However, companies will be permitted to apply the updated classification and labeling provisions on a voluntary basis before that date. For substances and mixtures that have already been classified and labeled under the current CLP requirements and placed on the market before the new provisions enter into force, an extended transitional period is foreseen. Such products will only need to comply with the new requirements 48 months after the regulation enters into force.
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