New Amendment to CLP Regulation (EU 2024/2865): Major Changes in Chemical Product Labeling

New Amendment to CLP Regulation (EU 2024/2865): Major Changes in Chemical Product Labeling

On November 20, 2024, Regulation (EU) 2024/2865, was announced, introducing modifications to Regulation 1272/2008 (CLP), which governs the classification, labeling, and packaging of substances and mixtures. The new text includes a series of significant changes affecting, among other things, the labeling and notification of chemical products in the European Union.

Here are some of the most important updates:

LABELING: New Rules and Deadlines

  • •A minimum font size is assigned based on container capacity (defined by the height of the letter x) and additional values for containers up to 0.5 liters (Section 1.2.1.4).
  • •Stricter rules are assigned for label format:
    • Printed in black on a white background.
    • Distance between two lines of at least 120% of the font size.
    • Use of a single, easily readable sans-serif font.
    • Adequate spacing between letters to ensure the selected font is easily readable.
  • •• Deadlines for updating labels are set (Article 30):
    • For a change in the classification or labeling of a substance or mixture that results in the addition of a new hazard class or a stricter classification: 6 months.
    • If the change is due to the harmonized classification of a substance (ATP): the date established in the regulation.
    • Other cases: 18 months.
  • •The use of fold-out labels for all products is allowed (Article 31), indicating their content specifically by page (Section 1.2.1.6).
  • •Voluntary digital labeling is allowed (which never exempts physical labeling) and explicit requirements for this are defined (Chapter 3: Labeling Models).
  • •Hazard categories are added to substances that contribute to classification (and therefore must appear on the label) (Article 36, Section 1):
    • Respiratory sensitization, categories 1, 1A, or 1B.
    • Endocrine disruption for human health, categories 1 or 2.
    • Endocrine disruption for the environment, categories 1 or 2.
    • Persistent, bioaccumulative, and toxic.
    • Very persistent, very bioaccumulative.
    • Persistent, mobile, and toxic.
    • Very persistent, very mobile.
  • •• Information that must appear on containers smaller than 10 ml is updated (Section 1.5.2).

PCN NOTIFICATION: Obligations for Distributors

To avoid loss of information, the obligation to submit for distributors when distributing hazardous mixtures in other Member States, re-labeling hazardous mixtures, or changing the brand is introduced (Article 45).

OTHER UPDATES OF THE Regulation (EU 2024/2865):

  • •Substances containing more than one component must be evaluated and classified according to the same classification rules as mixtures.
  • •Proposal for harmonized classifications for groups of similar substances.
  • •Advertising and distance selling (Article 48).
  • •Determination of supply conditions through refill stations for refillable products intended for consumers (Annex II, Section 3.4).
  • •Publication of the identity of the importer or manufacturer responsible for notification to the C&L inventory and the most recent date (Article 42).
  • •Addition of new hazard classes (Regulation 2023/707) and sub-categorization of respiratory sensitization 1A or 1B among the most concerning substances to prioritize their harmonized classification.
  • •In distance selling offers, the offer/advertisement must indicate the mandatory labeling elements (hazard pictograms, warning word, hazard statements, EUH, and the phrase: "Always follow the information on the product label.") (Article 50).

FUTURE CHANGES TO BE APPROVED

In Article 54, the following future revisions are proposed with a deadline of 5 years (December 2029):

  • •Addition of the hazard "Eye Injuries Cat.1" for child-resistant fastening.
  • •Examination of information on substances containing more than one component extracted from plants and their classification.

APPLICATION DEADLINES

The regulation (EU 2024/2865) comes into force on December 9, 2024, but will not be mandatory until the following dates (Article 61):

  • •From July 1, 2026: applicable to updating label information, fold-out/reduced labeling, digital labeling, labeling conditions at refill stations, public information of the C&L inventory, advertising/distance selling offers.
  • •From January 1, 2027: applicable to font size, label dimensions, line spacing, font type, color.