Regulation (EU) 2025/2439: Official Extension of Application Dates

The European Union has approved postponing the entry into force of the revised provisions of Regulation 1272/2008 (CLP), giving industry more time to adapt to the changes without compromising safety.

With the publication of Regulation (EU) 2025/2439 on 3 December 2025, the application deadlines for several CLP provisions have been extended, mainly affecting rules on labeling, advertising, and distance selling, as well as conditions for supply without packaging.

This adjustment is part of the “Omnibus VI” legislative package, aimed at ensuring an orderly transition and avoiding disruptions in the supply chain.

Below are the provisions that retain their original date and those that have been postponed, to facilitate regulatory planning.

Provisions entering into force on 1 July 2026 (unchanged date)

These measures mainly affect classification criteria and technical aspects of labeling:

• Adjustments to the classification and identification of substances (Art. 1 point 3(b)).
• Criteria for classifying multi-component substances and rules for applying the extrapolation approach and weight of evidence in assessing hazardous properties such as ED, PBT/mPmB, and PMT/mPmM (Art. 1 points 4–7).
• Deadlines for updating labels after classification changes: six months for major changes and eighteen months for minor changes (Art. 1 points 12(a) and 13).
• Definition of the format for voluntary digital labeling (Art. 1 points 15(a), 15(b), 17, 18, 22, 23).
• Mandatory supplementary indications for mixtures, which must appear on the label regardless of classification (Annex II point 1).

Provisions entering into force on 1 January 2027 (unchanged date)

These provisions impact specific classification and communication for health response:

• Updated classification criteria by physical form (Art. 1 points 1 and 9).
• Technical changes to harmonized information for health response (PCN), with adjustments to Annex VIII to improve data quality and interoperability (Art. 1 points 24(b) and 24(d) + Annex IV).

Provisions entering into force on 1 January 2028 (updated date)

This block includes the most demanding changes, related to labeling, sales, and commercial communication:

• Generalization of fold-out labels on packaging, with requirements on content per page and legibility (Art. 1 point 14).
• Establishment of a mandatory minimum format for labels, including minimum font size, black text on white background, and pictogram dimensions (Art. 1 point 15(c)).
• Obligations for advertising and distance selling, requiring hazard information to be displayed in online ads and offers (Art. 1 points 26 and 27).
• Technical details on digital label format, specifying which elements may appear digitally and under what conditions (Annex I points 2 and 3).
• Rules for dispensing without packaging and refill stations, including conditions for public supply and restrictions for certain hazard classes (Annex II point 2).

At Siam we closely monitor these updates to ensure our clients have clear and up-to-date information so they always comply with current regulatory requirements. For more information, you can consult our news article on the modernization of chemical labeling in the EU.