New Update on the CLP Regulation Passed by EU Parliament

When the Commission proposed revising the CLP Regulation in December 2022, many businesses in the Chemical industry wanted to know how they would be affected.

All updates throughout this article appear in red.

When the commission proposed revisigin the CLP Regulation in the December 2022, many businesses in the Chemical industry wanted to know how the would be affected.

Indeed, now that the Regulation has been approved, many are still wondering what that will mean for their business operations. 

We wrote this guide to give you a better understanding of the recently updated CLP Regulation. That way, you can ensure that your business meets the new requirements.

In just under four minutes, you’ll discover:

• What the CLP Regulation is
• An overview of the updates
• How it will affect chemical labelling in your business

What Is the CLP Regulation?

The CLP Regulation (Classification, Labelling, and Packaging of Substances and Mixtures) governs how chemical substances and mixtures are classified and labelled in the European Union.

It aims to offer the highest possible level of protection for both humans and the environment. 

In doing so, it protects consumers and workers who come into contact with chemical substances and mixtures. It also promotes the safe, free movement of substances and mixtures within the EU.

The CLP Regulation came into force on the 20th of January 2009.

The legislation requires businesses to properly classify, label, and package any chemicals before they reach the market. These regulations apply to manufacturers, importers, and downstream users.

To ensure a homogenous process, it follows the classification and labelling criteria agreed upon by the UN in the Globally Harmonised System of Classification and Labelling of Chemicals (GHS). 

To sum up, the CLP Regulation provides common safety conventions for labelling and packaging chemicals. That way, consumers and workers coming into contact with the substances can make informed handling and purchasing decisions. 

Changes to the CLP Regulation

During the Chemicals Strategy for Sustainability on the 19th of December 2022, the Commission proposed revising the current CLP Regulation.

It also argued in favour of introducing new hazard classes for other harmful substances, including endocrine disruptors.

The revised Regulation offers greater clarity on labelling issues, helping businesses comply with CLP when selling chemicals online.

Some of the main features of the revised CLP Regulation include:

• Specific rules for the safe use of refillable chemical products, such as home cleaning chemicals
• More efficient processes for informing relevant parties on the hazards of chemicals within the EU market
• Better communication surrounding chemical hazards, including clearer labelling and advertising requirements

This amended CLP Regulation also enables the Commission to create classification proposals on potentially hazardous substances, speeding up the identification of harmful chemicals.

The proposal has now been passed by the European Parliament and Council. 

How Will the Changes to the CLP Regulation Affect My Business?

Many of our clients want to know how these amendments will impact their businesses.

The updated CLP Regulation means there will be some modifications to labelling requirements in the Chemical industry.

Here are some of the most notable changes you should be aware of:

Fold-out Labels

Fold-out labels are to be permitted on a regular bases. “It is therefore appropriate to allow labels to be presented in a form of fold-out labels, applying the general rules on application and formatting to ensure where readability and specific requirements for form and design of the front page.”

In accordance with Article 17 the front page of a fold-out label must include:-

• Name, address and phone number of the supplier(s).
• Nominal quantity of substance or mixture in the package made available to the general public, unless this quantity is specified elsewhere on the package.
• Product identifiers in accordance with Article 18(2) for substances and Article 18(3)(a) for mixtures in all languages of the label that are used in the inside pages.
• 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 to the inner packaging in accordance with point 5, 3, PArt A in Annex VIII of the Regulation.
• A refrence to the full safety information inside the fold-out label in all languages of the label or 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.

Fonts and Text

Let’s start with the reason you’re all here: font sizes. 

According to the updated Regulation, there will be new minimum font sizes based on the size of the packages:

• Packages less than 0.5L → minimum font 1.2mm
• Packs greater than 0.5L up to 3L → minimum font 1.4mm. All packages smaller than 3L must have a minimum font size of 1.4mm in height. Where possible, the dimensions of the label should be at least 52mm x 74mm. Pictograms are to be no smaller than 10mm x 10mm, and where possible 16mm x 16mm.
• Packs greater than 3L up to 50L → minimum font 1.8mm. Packs greater than 3 litres but not exceeding 50 litres should have a minimum font size on 1.8mm in height. Where possible, the dimensions of the label should be at least 74mm x 105mm. Pictograms should be a minimum of 23mm x 23mm.
• Packs greater than 50L → minimum font 2.0mm. For packs greater than 50 litres, but not exceeding 500 litres, the minimum font size should be 2.0mm in height with a label of at least 105mm x 148mm. Pictograms should be at least 32mm x 32mm.
• For packs greater than 500 litres, the minimum font size should be 2.0mm in height with a label of at least 148mm x 210mm. Pictograms should be a minimum of 46mm x 46mm.

Important note: You can use smaller fonts for inner packaging if the contents are less than 10ml.

Label Formatting

Now for the bad news. Label formatting is back.

Following the new requirements, your business must:

• Have black text on a white background. 
• Use a fixed distance between text lines (120% of the font size). Distance between the lines should be appropriate for the selected font size and must be easily legible.
• Utilise a single font with no serifs.

In addition to the changes above, the formatting requirements and layout for fold-out labels will move from the guidance document to the legislation.

Digital labelling is to be accepted to a degree for certain elements and will be voluntary. However, these elements still need to be specified on a physical label.

Finally, based on scientific justification, labelling can cover groups of substances (rather than individual substances).

Digital Labelling

Perhaps the most significant update is the approval of the use of digital labelling in the form of a data carrier barcode or QR code.  This is aimed at improving the efficiency of hazard communication amongst vulnerable groups such as the visually impaired or whose first language does not match the language on the primary label  digital labelling:-

The label elements for substances and mixtures referred to in Article 17 shall be provided on a primary label in physical form.  Information may be provided in digital form following the following guidelines:-

A digital label does not replace a physical GHS label but can contain supplementary information.

• The data carrier (barcode/QR code) must be readable and accessible by a wide range of devices. Where a digital label is used, a data carrier to that digital label shall be firmly affixed or printed on the physical label or on the packaging next to the label in such a way that can be automatically processed by digital devices that are widely used.
• The digital label shall be firmly affixed next to a physical label or incorporated into the layout of a printed label for easily access.
• A statement such as “more hazard information is available online” or similar must accompany the data carrier.
• Supplier will make available, by oral or written request, this information by alternative means when the digital label is temporarily unavailable.  The data is to be supplied independently and free of charge.
• Digital information is to be searchable.
• Information is to be available to all users in the  Union and accessible for a minimum of 10 years or longer as required.
• There must be no need to download a document, install an app or provide a password to access information in no more than 2 clicks.
• Where more than 1 language is represented the choice of language must not be limited by geographic location from which the information is accessed. 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.

No tracking or analytic data is retained for other purposes such as marketing.

Deadline of Implementation

As a result of the new legislation, the following transition dates apply:

• For new products:
• Updating labels after a change of classification – 18 months after this regulation appears in the Official Journal – EU LEX. 20th May 2026.
• Rules for advertisements- 18 months after publication. 20th May 2026.
  Black text on white background (excluding other label formatting rules)- 18 months after publication. 20th May 2026.
• All other label formatting rules (including minimum font sizes)- 24 months after publication. 20th November 2026.

• For products already on the market with label formatting as the existing legislation in the 2 years following EU LEX publication  (20th November 2026), then you have 4 years after EU LEX publication. 20th November 2028.
• For products already on the market where the label elements need to change (because of the changes to the ‘contains’ statement, or the addition of the Endocrine hazards, PBT or PMT classes) then the timescale is less – 3.5 years. 20th May 2028.

Final Thoughts

We hope this update on the CLP Regulation gives you clarity on how these changes may impact your business. 

If you have any questions or concerns, get in touch to see how we can help you stay compliant.