EU proposes new amendments to the CLP Regulation to modernise chemical labelling: more flexibility, digitisation and extended deadlines

On 8 July 2025, the European Commission presented proposal COM(2025) 531, which affects Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP) , as well as Regulation (EC) No 1223/2009 on cosmetic products and Regulation (EU) No 2019/1009 on fertiliser products.

On 20 November 2024 the European Union adopted Regulation (EU) 2024/2865 which introduces a digital labelling system and partially amends the CLP Regulation, setting new rules on label format and relabelling deadlines. The proposal COM(2025) 531 aims to reduce the administrative burden and costs resulting from this amendment, to increase flexibility for businesses, especially SMEs, and to adapt labelling to current digital practices.

The main changes proposed to Regulation (EC) No 1272/2008 (CLP) are as follows:

1. Digital Labelling and Electronic Contact: he use of digital labelling will be allowed to facilitate communication with users and reduce the use of physical labels. The concept of ‘digital contact’ is introduced as an alternative to telephone or physical address on labels.
2. Simplified labelling for small packs: Reduced mandatory information will be allowed on labels on packs of less than 10 ml without the need to justify space limitations.
3. Flexible deadlines for updating labels: the fixed deadline of six months will be abolished. Labels will have to be updated ‘without undue delay’ upon receipt of new information.
4. More flexible label format: the rules on label format introduced in 2024 will be simplified, prioritising clarity and legibility over design.
5. Advertising and online sales: Mandatory information requirements in advertisements and online sales will be reduced, limited to critical warnings. Obligations are limited to products aimed at the general public.
6. Petrol stations: labelling requirements on fuel pumps are simplified, eliminating elements such as the UFI or the name of the supplier.

Concerning the Cosmetics Regulation (EC) No 1223/2009, it clarifies procedures and sets clear deadlines for exemptions of banned substances, provides guidance on products with CMR substances (carcinogenic, mutagenic or toxic to reproduction) and maintains the Commission's ability to act on health risks after consultation of the Scientific Committee on Consumer Safety.

For Fertiliser Regulation (EU) No 2019/1009, it removes extended registration requirements applying standard REACH rules and proposes clearer criteria for assessing micro-organisms in plant biostimulants, facilitating market access.

The Commission has also proposed a separate regulation, COM(2025) 526, which postpones until 1 January 2028 the entry into force of several provisions including label design and format, advertising rules and labelling for online and distance selling.

As a proposal, it has been sent to the European Parliament and the Council of the EU for review and it is necessary to wait for approval before having the final regulatory text. The unchanged parts will still come into force in 2026 or 2027, as foreseen from the beginning. Siam will be attentive to this legislative process in order to apply the resulting changes and facilitate the adaptation of companies to this new challenge.