EU CLP transition: formulation changes can end your grace period
Regulation (EU) 2024/2865 changed the CLP framework and, together with Delegated Regulation (EU) 2023/707, brought in new hazard classes (ED, PBT/vPvB, PMT/vPvM). Regulation (EU) 2025/2439 ("stop the clock") then postponed the label-format and advertising provisions to 1 January 2028. The classification duties for the new hazard classes were not postponed: substances already on the market are due on 1 November 2026, mixtures already on the market on 1 May 2028. The transition rules are not only about dates — placing a reformulated mixture on the market can end the grace period the original mixture relied on.
Published10 Sept 2026
Effective2024/2865 in force 10 December 2024; 2025/2439 ("stop the clock") in force 23 December 2025
Compliance deadline01 Nov 2026New hazard classes for substances already on the market: 1 November 2026. Label-format and advertising rules: postponed to 1 January 2028. A reformulation can remove a mixture's transitional protection.
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