On November 24th, 2024, the European Union introduced Commission Regulation 2024/2865, which updates the EU CLP Regulation. These revisions officially took effect on December 10th, 2024, with most requirements becoming mandatory by July 1, 2026, while the remaining changes will be enforced starting January 1st, 2027.
This amendment introduces significant updates to the Classification, Labelling, and Packaging (CLP) Regulation, aiming to improve chemical safety and ensure consistency with industry developments. One of the key updates includes new labelling rules that specify minimum font sizes, structured formatting, and defined line spacing to enhance clarity and compliance.
Obligatory Formatting Rules
Updates state that label elements should have the following characteristics:
- The text should be printed in black and the background of the text should be white;
- A single font should be used that is easily legible and without serifs;
- The letter spacing shall be appropriate for the selected font to be comfortably legible.
- The distance between two lines shall be equal, or above, 120% of the font size – for example, for a 20 point size font the line spacing must be 24 point, or above.
Minimum Font Sizes
The minimum font sizes have changed in several updates which, alongside the increased line spacing, will make it impossible to fit all of the required elements on the labels of some products at the current recommended size.
Font sizes have now been amended to be the following sizes:
For inner packaging, where contents are less than 10ml, smaller font sizes will be permissible as long as it remains “easily legible”.
Digital Labels
Suppliers linking to a digital label shall ensure that the digital label satisfies the following general rules and technical requirements:
- all label elements referred to in Article 17(1) shall be provided together in one place and separated from other information;
- the information on the digital label shall be searchable;
- the information on the digital label shall be accessible to all users in the Union and shall remain accessible for a period of at least 10 years, or for a longer period where required by other Union legislation;
- the digital label shall be accessible free of charge, without the need to register, download or install applications, or to provide a password;
- the information on the digital label shall be presented in a way that also addresses the needs of vulnerable groups and support, as relevant, the necessary adaptations to facilitate access to the information by those groups;
- the information on the digital label shall be accessible with no more than two clicks;
- the digital label shall be accessible through digital technologies widely used and compatible with all major operating systems and browsers;
- when the information on the digital label is accessible in more than one language, the choice of language shall not be conditioned by the geographical location when accessed.
Fold-Out Labels
The front page of the fold-out label shall include at least the following elements:
- name, address and phone number of supplier(s);
- 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 in accordance with point 5.3, Part A in Annex VIII of this Regulation;
- a reference to the full safety information inside the fold-out label in all languages of the label, or a symbol to inform a 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 label elements provided for in Article 17(1), 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 abbreviation (country code or language 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.
Labelling Products Sold Online
When substances or mixtures are placed on the market through distance sales, such as online, the offer shall clearly and visibly indicate the label elements referred to in Article 17.’
It is proposed that the same classification, labelling and packaging obligations should apply to online sales and that chemicals sold online, in the EU market, must be in compliance with the CLP regulations. This means that there would be an obligation for the advertisement to contain the hazard pictogram, signal word, the hazard class, and the hazard statements.
Advertisements
Any advertisement for a substance classified as hazardous must indicate the hazard pictograms, signal word, hazard statements and supplemental EUH statements set out in Annex II. Any advertisement for a substance for sale to the general public must, in addition, state “always read and follow the information on the product label“.
Any advertisement for a mixture classified as hazardous, or covered by Article 25(6), shall indicate the hazard pictograms, signal word, hazard statements and supplemental EUH statements set out in Annex II. Any advertisement for sale of mixtures to the general public shall, in addition, indicate “always read and follow the information on the product label“.
Any advertisement for a substance or a mixture classified as hazardous shall not contain statements that shall not appear on the label or packaging of that substance or mixture in accordance with Article 25(4).
The hazard pictograms and signal word may be omitted where the advertisement is ‘non-visual’.
Tactile Warnings & Child-Resistant Fastenings
Within 5 years, the Commission has proposed to assess the effectiveness of the provisions regarding tactile Warnings and child-resistant fastenings. They may extend provisions to other hazard classes, in particular the requirements for child-resistant fastenings to eye damage category 1.
The changes, if found necessary, would be adopted through a delegated act amending Annex II without the need for further voting.
Changes to Deadlines for Updating Information on Labels
After a change to the classification or labelling: If the classification becomes more severe, or new supplemental information is added to the label, the supplier must update the labels without undue delay – and no later than 6 months.
For any other change to the classification or label, the label must be updated without undue delay – and no later than 18 months.
If any changes are triggered by a harmonised classification covered by an ATP, then the date(s) specified in the ATP take precedence.
If the label falls under the biocide or detergent regulations then any specified timeframe within those regulations take precedence.
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.
If the label falls within the biocide or detergent regulations, then it is the timeframe specified within those regulations take precedence.
Points of Note
- The new label format changes will only apply in the EU, and not in the rest of the GHS jurisdictions worldwide.
- The changes will apply in Northern Ireland under the terms of the NI Protocol. This is subject to further developments under the Northern Ireland Protocol Bill or through negotiations with the EU.
Further information and related links
For further information refer to the official text of Regulation (EU) 2024/2865.
Prepare now: Key Deadlines for Compliance with updated CLP Regulations.
CLP minimum font sizes for labels & converting the size from millimetres to points.
How Can Hibiscus Help?
Hibiscus Plc has been providing labelling solutions for the chemical and hazardous goods industries for over 40 years.
Our ‘Enterprise” Chemical Labelling software is fully updated to future-proof your label production and make it easier to comply with the new label regulations.
See how we can improve your hazard communication compliance and keep you up to date!
Call us today: 0113 242 4272 | enquiries@hibiscus-plc.com
