The Blog

Regulatory Compliance Update

The European Union’s Classification, Labelling and Packaging Regulation (CLP Regulation) has entered an important new phase. Businesses supplying chemical substances in the European Union must now prepare for the next major compliance deadline: 1 November 2026.

This transition date applies to qualifying substances that were placed on the EU market before 1 May 2025. New quantities placed on the market since 1 May 2025 are already subject to the new requirements.

Why were new CLP hazard classes introduced?

The CLP Regulation, Regulation (EC) No 1272/2008, establishes the EU framework for identifying and communicating the hazardous properties of substances and mixtures. It governs how chemical hazards are classified and how those hazards are communicated through labels and packaging.

As scientific understanding developed, EU authorities identified a need for legally binding classifications covering substances that may disrupt endocrine systems or remain in and move through the environment for long periods. Regulation (EU) 2023/707 amended CLP by adding new hazard classes and corresponding classification and labelling criteria.

What are the new CLP hazard classes?

• Endocrine disruption: human health (EUH380 / EUH381)
• Endocrine disruption: environment (EUH430 / EUH431)
• PBT and vPvB (EUH440 / EUH441)
• PMT and vPvM (EUH450 / EUH451)

Fact-checked CLP deadline timeline

• 1 May 2025: New quantities of substances placed on the EU market must comply with the new hazard-class requirements.
• 1 May 2026: New quantities of mixtures placed on the EU market must comply with the new requirements.
• 1 November 2026: The transition ends for qualifying substances placed on the market before 1 May 2025.
• 1 May 2028: The transition ends for qualifying mixtures placed on the market before 1 May 2026.

Who is affected?

• Chemical manufacturers in the EU
• Non-EU companies supplying chemicals into EU
• EU importers
• Downstream users and formulators
• Distributors
• Suppliers of active substances for biocidal products
• Suppliers of active substances for plant protection products

Seven actions to take before 1 November 2026

1. Assess all your substances
2. Assess every new hazard class
3. Review mixture classifications
4. Update labels and packaging if required
5. Update Safety Data Sheets if required
6. Review regulatory submissions such as EU REACH registrations
7. Retain the classification rationale

Additional implementation considerations

• Self-classification responsibilities

Common compliance mistakes to avoid

• Assuming 1 November 2026 is the first compliance date for all substances.
• Assuming every mixture has update time until 1 May 2028.
• Treating the transition as product-wide rather than stock-specific.
• Updating labels without reassessing the classification.
• Waiting for suppliers without an escalation plan.

Final takeaway

The 1 November 2026 CLP deadline is a major milestone for qualifying substances placed on the EU market before 1 May 2025. Businesses relying on the transition should now be completing scientific assessments, classification decisions, labels, Safety Data Sheets and regulatory updates.

Authoritative sources

1. Commission Delegated Regulation (EU) 2023/707.
2. European Chemicals Agency: New hazard classes 2023.
3. Corrigendum to Commission Delegated Regulation (EU) 2023/707.
4. ECHA: Classification of substances and mixtures.