The Classification, Labelling and Packaging Regulation, commonly known as the CLP Regulation, establishes the rules for classifying, labelling and packaging chemical substances and mixtures placed on the European Union market.
Regulation (EC) No 1272/2008 implements the United Nations GHS framework within the EU.
Manufacturers, importers and downstream users are required to identify the hazards associated with substances and mixtures and ensure that appropriate classification and hazard communication requirements are applied before products are placed on the market.
New Hazard Class for Chemicals Under Pressure
One of the most notable changes proposed in the draft is the introduction of a new physical hazard class for “chemicals under pressure.”
The new category is intended to cover certain liquids and solids maintained under specified pressure conditions.
Its introduction is expected to provide a more specific and consistent framework for classifying hazards associated with chemicals stored or used under pressure.
Changes to Aerosol and Explosive Classification
The proposal also includes revisions to the classification criteria applicable to aerosol products.
Changes are additionally planned for the criteria used to categorise explosive substances and mixtures.
These amendments aim to improve alignment between the EU CLP Regulation and the latest GHS revisions while increasing consistency in the assessment of physical hazards.
Greater Use of Non-Animal Testing Methods
The draft introduces important changes to the assessment of health hazards.
One of the key objectives is to reduce reliance on animal testing by giving greater priority to alternative methods and non-animal data.
Tiered assessment frameworks are proposed for health endpoints including:
- Skin corrosion and irritation
- Serious eye damage and eye irritation
- Skin sensitisation
These frameworks are intended to allow available scientific information to be assessed systematically before additional testing is considered.
In Vitro and Alternative Methods Gain Greater Importance
The proposed CLP revision places increased emphasis on in vitro methods, alternative testing strategies and integrated scientific evidence.
Where scientifically appropriate, validated non-animal methods and existing data may play a greater role in determining hazard classifications.
This represents an important development for industries that increasingly rely on alternative approaches to chemical safety assessment, including chemicals, cosmetics, personal care and consumer products.
Hazard and Precautionary Statements to Be Updated
The proposed revision also includes extensive changes to hazard communication requirements.
In particular, several precautionary statements are expected to be added, revised, consolidated or removed.
The changes are intended to:
- Improve readability
- Reduce unnecessary duplication
- Increase consistency
- Support more practical application of hazard information
across chemical labels and supply-chain communication.
Product Labels and Safety Data Sheets May Need Updating
Changes to CLP classification criteria and hazard communication requirements may have significant downstream implications for businesses.
Companies may need to review or update:
- Product labels
- Safety Data Sheets (SDS)
- Hazard statements
- Precautionary statements
- Hazard pictograms
- Packaging requirements
- Supply-chain documentation
Businesses placing chemical substances and mixtures on the EU market should therefore monitor the proposed revision closely.
WTO Comment Period Ends on 16 October 2026
Under the WTO notification procedure, WTO members and interested stakeholders may submit comments on the proposed measure until 16 October 2026.
The European Commission is expected to review the feedback received before finalising the regulatory text.
24-Month Transition Period Expected
If the proposed amendments are adopted, the revised requirements are expected to become mandatory following a 24-month transition period after publication in the Official Journal of the European Union.
Additional transitional provisions are also expected for substances and mixtures already placed on the market under the existing CLP requirements.
The transition period is intended to give businesses sufficient time to update classification, labelling, packaging and regulatory documentation.
What Does the CLP Revision Mean for Businesses?
The proposed CLP Regulation revision could have significant implications for manufacturers, importers, downstream users and other businesses placing chemicals or chemical-containing products on the EU market.
Companies should consider:
- Identifying substances potentially affected by new hazard classifications
- Reviewing existing CLP classifications
- Assessing product labels and Safety Data Sheets
- Monitoring revised hazard and precautionary statements
- Evaluating new requirements for alternative testing approaches
- Incorporating transition periods into regulatory compliance planning
The proposed revision represents a significant step in the continued alignment of the EU CLP Regulation with the evolving UN GHS framework.
Businesses operating in the European chemicals market should therefore closely monitor the legislative process and prepare for potential changes to their classification, labelling and hazard communication obligations.