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New CLP Hazard Classes: are your chemicals compliant?

03 Apr 2025

The first deadline for the implementation of the new CLP hazard classes is almost upon us. From 1 May 2025 suppliers must assess the hazards of chemical substances placed on the market to see if they meet the new criteria, and if applicable, label them accordingly.

ECHA clarified at the end of 2024 that the new criteria must be applied from this date to all new substances, including new batches of existing substances.

A further 18-month transition period – until 1 November 2026 – will only apply to existing substances already placed on the market (i.e. substances that were produced, packaged and labelled) before this date.

What happens after the deadline?

Obligations do not end after the deadline. Suppliers need to remain aware of any new information that may affect classification, and carry out new hazard assessments as required. Therefore, organisations have a continuing requirement to stay on top of new information through monitoring of sources, including new and updated harmonised classifications and classification proposals, updates to REACH registration dossiers, assessments by ECHA and national authorities.

CLP does not require any new testing to be carried out for the new hazard classes, only assessment of existing data. Other regulations, including REACH, may require further testing, however, and a high percentage of the substances on the recently updated CoRAP list include substances suspected of having endocrine disrupting properties or PBT/vPvB or PMT/vPvM properties as initial grounds for concern.

New REACH testing requirements for endocrine disruptors are also under discussion and updates to Annexes VII-X are expected soon.

Deadline for Mixtures

Formulators who produce mixtures should be preparing for the associated deadline, 1 May 2026. ECHA clarified in 2024 that the extended transition period until 1 May 2028 will only apply to products placed on the market before 1 May 2026. Any new mixtures and new batches of existing mixtures must be assessed for the new hazard classes from 1 May 2026, and if applicable labelled accordingly.

Formulators need to ensure that they are keeping up to date with any new information provided by their raw material suppliers, as well as the activities of ECHA as outlined above.

How will these deadlines impact your regulatory compliance?

The new criteria may require new labels and SDS, but suppliers may also need to update:

REACH Registration dossiers
Classification and Labelling Inventory Notifications (for substances)
Poison Centre Notifications (for mixtures)

In the Q&A published following ECHA’s webinar last year, they clarified that once a substance has been assessed against the classification criteria in the new hazard classes, if the substance is already classified in any hazard class that previously required a notification to be submitted, the existing notification needs to be updated with information on how the new hazards were assessed, even if the additional assessment for the new hazard classes does not lead to classification because it does not meet the criteria for classification for these hazard classes, or if the conclusion is that there is insufficient data to decide on a classification. If a previously unclassified substance now meets the criteria for classification in the new hazard classes, this will now need to be notified to the C&L inventory.

Expert support to minimise regulatory risk

Should you require any support to ascertain the impact of these deadlines on your organisation or require support in making any notifications in the EU or beyond, please contact our regulatory experts today.