EU CLP transition: formulation changes can end your grace period

What changed

Three instruments interact:

• Delegated Regulation (EU) 2023/707 introduced the new hazard classes — endocrine disruptors (ED), persistent/bioaccumulative/toxic and very persistent/very bioaccumulative (PBT/vPvB), and persistent/mobile/toxic and very persistent/very mobile (PMT/vPvM).
• Regulation (EU) 2024/2865 revised the CLP Regulation itself (label formatting, advertising and distance-sales information, digital labelling, poison-centre and ATP alignment) and confirmed the new hazard classes in the base text. In force 10 December 2024.
• Regulation (EU) 2025/2439 — the "stop the clock" amendment — postponed the label-format and advertising provisions to 1 January 2028. In force 23 December 2025.

Key application dates for the new hazard classes (not postponed by 2025/2439):

Label-format and advertising rules from 2024/2865: 1 January 2028 (transitional stock to 1 January 2030 in the relevant cases).

The point that is easy to miss

Transitional protection attaches to product that is already in the supply chain. If you reformulate a mixture — change a component, a concentration, or a supplier that changes the composition — the mixture placed on the market after that change is a different mixture and must meet the current CLP requirements from that point. The grace period the original recipe relied on does not carry over.

Who is affected

• Substance registrants who must screen portfolios against the ED / PBT / PMT criteria for the 1 November 2026 date
• Formulators planning recipe or supplier changes during the transition window
• Brand owners holding legacy stock who need evidence of when it was placed on the market

Recommended actions

• Maintain a substance and mixture transition calendar with the applicable date per product.
• Treat every planned formulation or supplier change as a compliance trigger: re-check classification, SDS and label against current CLP before the changed mixture ships.
• Keep legacy-stock evidence — placed-on-the-market dates and volumes — so transitional claims can be supported.
• Apply SDS and label version control so the compliant version for each date is identifiable.
• Assess readiness for the new EU hazard classes now, not at the deadline, and align supplier and customer communication.