REACH & CLP Changes 2025-2026: Compliance Guide

Key EU REACH and CLP regulatory deadlines for 2025 and 2026, including new hazard classes, digital labelling rules, and required SDS updates.

The European Union's chemical regulatory framework is undergoing its most significant overhaul in more than a decade. Driven by the European Commission's Chemicals Strategy for Sustainability (CSS), substantial changes to both the CLP Regulation (EC No 1272/2008) and the REACH Regulation (EC No 1907/2006) take effect between 2025 and 2026.

Manufacturers, importers, downstream users, and distributors placing chemical substances and mixtures on the EU/EEA market must adapt their hazard classifications, packaging, Safety Data Sheets (SDSs), and supply chain communication to maintain market access.

New CLP Hazard Classes: Deadlines and Rules

Commission Delegated Regulation (EU) 2023/707 introduced new hazard classes into the CLP Regulation. These address environmental and human health endpoints that previously lacked dedicated classification criteria:

Transition Timelines

Businesses face staggered transition periods depending on whether a product is a substance or a mixture, and whether it was already on the market:

When these classifications apply, suppliers must assign the corresponding EUH statements (such as EUH430 for ED HH Category 1 or EUH440 for PBT) and update their ECHA Classification & Labelling (C&L) notifications within six months of any classification change.

The Revised CLP Regulation: Labels, Packaging, and Online Sales

The overarching revision of the main CLP text (agreed in 2024 and phasing into application through 2025–2026) introduces operational obligations beyond pure hazard identification:

Formatting and Minimum Font Sizes

To improve label legibility, the revised regulation establishes strict physical formatting parameters, including minimum font sizes, line spacing, and contrast ratios based on package capacity. Fold-out labels face tighter restrictions and must satisfy specific usability criteria.

Distance and Online Sales

Online chemical sales face stricter enforcement. Any digital storefront, B2B procurement portal, or e-commerce listing selling hazardous chemicals to customers in the EU must display all mandatory CLP label elements—hazard pictograms, signal words, hazard statements, and supplemental EUH statements—before the purchase is concluded.

Digital Labelling

Suppliers may choose to provide certain non-critical label elements via a digital label (such as a QR code or URL link). However, core safety information—hazard pictograms, signal words, hazard statements, and mandatory contact details—must remain visible on physical packaging.

Poison Centre Notifications (PCN)

Distributors and formulators must continue validating unique formula identifiers (UFIs). The final transitional period for industrial-use-only mixtures under Annex VIII to CLP ended on 1 January 2025. All hazardous mixtures placed on the EU market must now hold an active, validated PCN dossier with an accurately assigned UFI on the physical label or in Section 1.1 of the SDS.

REACH Developments: Restrictions and Revision

Alongside CLP updates, the REACH framework continues to tighten chemical controls across the European Economic Area:

Impact on Safety Data Sheets (SDSs)

Under REACH Annex II (as amended by Regulation (EU) 2020/878), Safety Data Sheets must accurately mirror updated CLP classifications:

When a substance or mixture is reclassified under the 2025–2026 rules, suppliers must update and issue revised SDSs to downstream recipients without undue delay.

Practical Compliance Checklist for 2025–2026

  1. Screen your inventory: Identify all raw materials, intermediates, and finished goods containing substances that meet ED, PBT/vPvB, or PMT/vPvM criteria.
  2. Engage upstream suppliers: Request written confirmations and updated SDSs to establish whether raw material classifications will change by the 2025–2026 deadlines.
  3. Review digital storefronts: Update product listings on web shops and digital catalogues to show CLP label elements prior to checkout.
  4. Audit physical packaging: Verify font sizes and formatting against updated CLP readability standards, adjusting label layouts where necessary.
  5. Check PCN and UFI validity: Ensure all hazardous mixtures are notified via the ECHA submission portal and that corresponding UFIs appear on labels and Section 1 of SDSs.
  6. Update SDS libraries: Replace obsolete SDSs with compliant versions and maintain records of downstream distribution.

FAQ

What are the main new hazard classes introduced under CLP?

Commission Delegated Regulation (EU) 2023/707 added three primary hazard categories: Endocrine Disruptors (for human health and the environment), Persistent, Bioaccumulative, and Toxic (PBT) / very Persistent, very Bioaccumulative (vPvB), and Persistent, Mobile, and Toxic (PMT) / very Persistent, very Mobile (vPvM).

When must existing substances comply with the new hazard classes?

Substances already placed on the EU market prior to 1 May 2025 have a transitional period ending on 1 November 2026, after which they must be classified, labelled, and packaged according to the new hazard criteria.

Do the new CLP rules apply to online sales?

Yes. The revised CLP Regulation mandates that online listings and distance sales platforms must display the hazard pictograms, signal words, hazard statements, and EUH statements clearly to the customer before the purchase transaction takes place.

Does the new classification require updating Section 2 of the SDS?

Yes. Any new hazard classification (such as ED HH, ED ENV, PBT, or PMT) and its associated EUH statements must be documented in Section 2.1 and 2.2 of the Safety Data Sheet, with supporting data integrated into Sections 3, 11, and 12.

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