Understanding Chemical Classification, Labelling and Packaging Requirements
The CLP Regulation sets the EU rules for how suppliers classify, label and package hazardous chemicals. The revised version has applied since 10 December 2024 and adds new hazard classes to improve how hazards are identified and communicated. Other parts of the revision now take effect later than first planned.
This guide explains the core requirements, the dates that matter and the checks importers should run before shipping to Europe.
What the CLP Regulation Covers
CLP stands for classification, labelling and packaging. It is Regulation (EC) No 1272/2008, which applies the Globally Harmonised System in the EU. The 2024 revision, Regulation (EU) 2024/2865, amends that original text.
Classification
Suppliers must assess each substance or mixture against defined hazard criteria. The result decides which label elements and packaging rules apply. That classification also feeds Section 2 of the safety data sheet, so the two documents must agree.
Labelling
The label is the first warning a user sees. It carries the product identifier, hazard pictograms, a signal word, hazard statements, precautionary statements and supplier details. Supplier details include the name, address and telephone number.
Packaging
Packaging must hold the contents safely and resist attack by them. Certain hazardous products also need child-resistant fastenings or tactile warnings of danger. Check these points with the producer before you order.
New Hazard Classes and the November 2026 Milestone
The new classes cover endocrine disruptors for human health and the environment, persistent, bioaccumulative and toxic substances, and persistent, mobile and toxic substances, including their very persistent variants. Some suppliers may need to reclassify products they have sold for years.
Transition Dates for Substances and Mixtures
1 May 2025: New substances placed on the market must comply with the new hazard classes. Substances already on the market had until 1 November 2026.
1 May 2026: New mixtures must be classified under the new classes. Mixtures already on the market have until 1 May 2028.
Buyers of existing substances should now expect updated labels and safety data sheets that reflect the new classes. Ask suppliers to confirm in writing whether any reclassification applies.
Label Content and the New Format Rules
Supplier Identification
The supplier named on the label must be established in the EU and act in an industrial or professional activity. This applies from 1 July 2026. Non-EU producers should confirm which EU importer appears on each label.
Formatting Rules Moved to 2028
A regulation published in the Official Journal in December 2025 postponed the label format rules to 1 January 2028. These cover font type, minimum font size and similar requirements. The relabelling obligation moved to the same date.
The revision sets a six-month limit to update a label after a new evaluation. That duty now applies from the same 2028 date. The minimum font heights stay as set in the revision:
1.2 mm for packs up to 0.5 litres.
1.4 mm for packs above 0.5 litres and up to 3 litres.
1.8 mm for packs above 3 litres and up to 50 litres.
2 mm for packs above 50 litres.
Confirm the final legal text before you reprint labels or order new packaging.
Digital Labels, Refills and Online Sales
The revision modernises how hazard information reaches users. Five changes matter most for trade:
Digital labelling: Suppliers may provide certain non-critical safety information in digital form.
Digital contact: This means an up-to-date online channel that reaches the supplier without registration or an app download.
Fold-out labels: These are permitted regardless of package size.
Refill stations: Products with any category of acute toxicity or specific target organ toxicity cannot go through refill systems.
Online sales and advertising: The new obligations now apply from 1 January 2028.
The United Kingdom did not adopt the revision, so labels for the EU and Great Britain can differ for the same product. Check each destination separately.
What Importers and Buyers Should Check Now
Start with the documents you already hold. Work through this list in order:
Ask each supplier whether the new hazard classes change the classification of your products.
Compare the label classification with Section 2 of the safety data sheet.
Confirm the EU-established supplier named on the label.
Check packaging for child-resistant fastenings and tactile warnings where required.
Plan label and packaging changes ahead of the 1 January 2028 formatting date.
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