Hibiscus is pleased to introduce Louise Witter as a guest blog contributor. Louise has extensive expertise in chemical regulatory compliance, with a particular focus on EU chemical legislation and classification and labelling requirements.
In this article, she explains the recent changes to EU CLP labelling formats and implementation deadlines, outlining what businesses need to know to stay compliant. She also highlights the key transitional timelines and practical implications of the updated requirements, helping organisations prepare for upcoming regulatory changes.
EU CLP Article 31(3) and Annex I 1.2.1 – Preparing for 1 January 2027
The European Union is introducing significant changes to chemical labelling under the EU CLP Regulation, following the adoption of Amendment 2024/2865. These revisions enhance, mandatory formatting requirements for labels that chemical suppliers should begin planning for now to meet the application deadline 1 January 2027. Here’s what you need to know about the deadlines of the labelling format amendment and its implications:
The Basics: What’s Driving the Change?
The amendment was adopted on 10 December 2024 and entered into force 1 January 2025 and introduces updates to Article 31(3) of EU CLP. While part of the amendment facilitates the implementation of Delegated Act 2023/707 (notably introducing endocrine disruption, PMT & PBT classifications), the focus here is on more routine regulatory updates – specifically, changes to label formatting as they impact standard, non-exempted, physical labels.
The New Formatting Rules
While the amendment doesn’t alter the core information that must appear on a label, it specifies how that information must be displayed. This includes:
- Minimum font sizes
- Black text on a white background
- Standardised spacing between lines
- Use of a single sans-serif font
- Specific rules on letter spacing
The goal is to improve readability and consistency across labels, but suppliers will need to review their artwork and printing methods to ensure compliance.
Timelines and Transitional Pathways
Although the amendment is already in force, there are transitional arrangements to allow the supply chain to adapt without blocking provision. There are two main pathways with their own deadlines:
- Time for the whole supply chain to comply – which can include continuing to place products on the market in non-compliance with 2024/2865 labelling requirements while new templates are rolled out
- For existing stock – which was in compliance with the outgoing labelling regulations as at 9 December 2024
In both cases, the products can only be placed on the market until 31 December 2026
In the case of ‘whole supply chain’ scenarios, the new labelling format requirements must be met by 1 January 2027. Subsequent arrangements may include activities to relabel product placed on the market in the transitional period.
In the case of the ‘existing stock’ scenario, physical units can be run down in the supply chain until 31 December 2028 with any remaining stock to be in compliance by 1 January 2029. If any of this stock remains on the market, arrangements may include recall of non-compliant units for the purposes of relabelling.
Use of both pathways could result in Product A being placed on the market with identical, outgoing labels but with application of different compliance deadlines. Clearly, the ability to demonstrate the date on which ‘existing stock’ Product A was physically labelled is critical to establishing the right to the extended compliance date.
From 1 January 2025 – 31 December 2026, newly compliant Product A may also be placed on the market!
Each pathway has its own deadline, so careful attention to detail is critical. CLP Ltd have produced a flowchart to guide suppliers through these transition periods—suppliers are encouraged to consult it as a planning tool. (DOWNLOAD a high-resolution copy).
Who Needs to Act?
The obligation to comply with the updated labelling requirements rests with suppliers. This includes:
- Manufacturers
- Importers
- Distributors
- Downstream users
placing products on the EU market.
The whole supply chain is bound by the same transitional period so there are diminishing returns in postponing change. It is highly likely that suppliers nearer the end of the chain, e.g., retailers, will pressurise the upstream suppliers for early compliance.
In addition, non-compliant labels will be fairly evident to inspectors and regulators.
Proactive compliance is key.
A ‘Reality Check’?
During May 2025, a workshop was facilitated by the European Commission and attended by various stakeholders, to introduce new tool ‘Reality Check’. The tool is designed to support the Commission’s simplification policy and drive initiatives.
Discussions included the label format requirements brought into EU CLP via Amendment 2024/2865. The minutes indicate that ‘many called for a pause in their implementation’ and that many supported simplifying business to business labels on the basis of access to safety data sheets. Stakeholders have been invited to submit quantifiable evidence to support any simplification proposals by 1 June 2025. The Commission will then prepare a report to inform policy.
Next Steps for Suppliers
- Identify stock existing & labelled as at 9 December 2024 which could be managed out of the supply chain using the extended deadline
- Audit your current label formats for all products subject to EU CLP
- Check the specific formatting requirements introduced under Article 31(3)
- Update artwork and production processes to meet the minimum technical specifications
- Coordinate with supply chain partners to align timelines and avoid disruption
- Monitor further guidance from ECHA as well as the outcomes of the simplification policy workshops
Sign up to the EU CLP Labelling and Packaging bundle: email requests@clpeu.com
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