Prepare Now: Key Deadlines for Compliance with Updated CLP Label Regulations

On 24th November, 2024, the European Union published Commission Regulation 2024/2865, which amended the EU CLP Regulation.  The amendments came into force on 10th December, 2024, with most provisions becoming mandatory on 1st July, 2026.

This regulation introduces several significant updates to the Classification, Labelling, and Packaging Regulation, aimed at improving chemical safety and adapting to evolving market practices. Notably, this amendment introduces new labelling criteria, including specified minimum font sizes, formatting and line spacing requirements.

Here’s a simplified overview of these changes and their respective deadlines:

Key Changes to the CLP Regulation

Label Formatting and Font Requirements:

• Font Size & Label Dimensions: New minimum font sizes and label dimensions to enhance label readability.  (see the minimum font size chart).
• Labels for packaging under 3 litres now split into two categories: Those under 0.5 litres, and those greater than 0.5 litres but less than or equal to 3 litres.
• Line Spacing & Font Type: Labels must use a sans-serif font that is easy to read, with line spacing set to at least 120% of the font size (not the font x-height).
• Letter Spacing: The letter spacing shall be appropriate for the selected font to be easily legible.
• Colour Specifications: Text must be black on a white background.

Fold-Out and Reduced-Size Labels:

• Fold-out labels and reduced-size labels are now allowed for small packaging, ensuring that all necessary information is provided even in limited space.  The front page of the fold-out label must include the following elements:
  • name, address and phone number of supplier
  • where applicable, hazard pictograms
  • where applicable, signal words in all languages of the label that are used in the inside pages
  • where applicable, the unique formula identifier, unless printed or affixed on the inner packaging.
  • a reference to the full safety information inside the fold-out label in all languages of the label, or a symbol to inform the user that the label can be opened and to illustrate that additional information is available on inside pages
  • an abbreviation of the language (country code or language code) for all the languages that are used in the inside pages.

  The inner pages of the fold-out label shall contain all the required label elements, except for the hazard pictogram and the supplier identification, in each of the languages mentioned on the front page and grouped by language, using the language country code.

  The back page of the fold-out label shall contain all the label elements provided on the front page, except for the abbreviations of the languages that are used in the inside pages.

Digital Labelling:

• In addition to physical labels, supplementary information may now be provided digitally. This digital information is voluntary but must adhere to strict requirements. Only those elements that are not instrumental to the protection of health, safety and the environment may be provided digitally, and a physical version of the information must be provided on request. Digital labels must be made available free of charge and ensure that the information is accessible ‘with no more than two clicks’.

Labelling at Refill Stations:

• New rules have been introduced for the safe handling and labelling of chemical products at refill stations.

Time Limits for Label Updates:

• Suppliers are required to update labels within six months when there is a change in classification or labelling that results in a new hazard class or more severe classification.
• For other classification or labelling changes, the supplier must update the label within 18 months of receiving new assessment results.
• For substances or mixtures regulated as detergents or biocidal products, the effective dates in those regulations take precedence.

Botanical Substances Exemption:  

• The amendment also establishes a five-year exemption for unmodified botanical-origin substances with multiple constituents (MOCS), allowing time for further scientific evaluation and potential new legislation.

Phased Implementation Deadlines

The new font sizes, formatting, and line spacing applies to labels from 1st January 2027.

There are also two transitional provisions that apply.

• By 1st July 2028 (Article 61(7)): New CLP rules apply to substances and mixtures placed on the market before 1st July 2026.
• By 1st January 2029 (Article 61(8)): New CLP rules apply to substances and mixtures placed on the market before 1st January 2027.

Prepare Now to Meet Upcoming Deadlines!

In light of the new regulatory changes, now is the perfect time to review and update your labelling processes.  The final legal text and deadlines have been published, so it’s time to think about starting to review and update the font sizes and line-spacing on your labels. Ensure any text is black on a white background and not impeded by any other part of the label design. Read more about the Minimum Font Heights and Line Spacing.

You should review the CLP regulations carefully to establish what impacts your business: For detailed information, refer to the official text of Regulation (EU) 2024/2865.