Message

A chemical has had the same designation for years. Nevertheless, its classification, label, and required product information can change. The reason is not necessarily a new formulation, but often adjusted legal requirements.

For manufacturers, importers, formulators and distributors, 2026 is an important transition year. Particularly relevant are the new EU hazard classes, which become mandatory on 1 May 2026 for mixtures placed on the market for the first time. At the same time, a transition period for certain substances that were already on the market before May 2025 ends on 1 November 2026. Other parts of the major CLP reform, such as new requirements for label design and distance selling offers, have been postponed to 1 January 2028.

This guide shows which changes will actually be relevant in 2026, who they affect, and which documents companies should check now.

What does the CLP Regulation cover?

CLP stands for Classification, Labelling and Packaging, in German: Classification, Labelling and Packaging.

The European CLP Regulation establishes uniform rules on how dangerous substances and mixtures:

• classified,
• labeled,
• packaged,
• communicated within the supply chain

must be.

The classification describes what hazardous properties a substance or mixture possesses. These include, for example:

• Flammability,
• acute toxicity,
• Corrosivity,
• Sensitization,
• Carcinogenicity,
• Hazard to the aquatic environment.

The classification results in the labeling elements on the product label. These may include:

• Product identifier,
• Hazard pictograms,
• Signal word,
• H-statements,
• P-statements,
• supplementary hazard statements,
• Supplier information.

The CLP Regulation applies directly in all member states of the European Union. It is largely based on the United Nations' globally harmonized system, the UN-GHS, but now also contains additional hazard classes that initially apply only in the EU.

Why is 2026 important for companies?

Several changes are running in parallel in connection with the CLP Regulation. That is exactly what makes the topic confusing.

Two reform steps must be separated from each other:

New hazard classes from Regulation (EU) 2023/707

These hazard classes affect, among others:

• endocrine-disrupting properties,
• Persistence and bioaccumulation,
• high mobility in the environment.

The new rules already apply to certain substances. For mixtures placed on the market for the first time, mandatory application begins on 1 May 2026. For certain substances that were already placed on the market before 1 May 2025, the transition period ends on 1 November 2026.

Comprehensive CLP revision from Regulation (EU) 2024/2865

This reform affects, among other things:

• the design of labels,
• digital labeling,
• Folding labels,
• Advertising,
• Online offers and distance selling,
• refill stations,
• Deadlines for updating labels,
• Substances with multiple constituents.

Some of these rules have already been in effect since 10 December 2024. However, certain requirements regarding labeling, advertising and distance selling were postponed to 1 January 2028 by Regulation (EU) 2025/2439.

For companies, this means: It is not enough to speak generally of the "new CLP rules 2026". Each specific obligation must be checked with its own application date.

Which new hazard classes were introduced?

With Delegated Regulation (EU) 2023/707, additional hazard classes were added to the CLP Regulation.

They concern:

• endocrine disruption with effects on human health,
• endocrine disruption with effects on the environment,
• persistent, bioaccumulative and toxic substances – PBT,
• very persistent and very bioaccumulative substances – vPvB,
• persistent, mobile and toxic substances – PMT,
• very persistent and very mobile substances – vPvM.

These classes are intended to capture hazards that were not always sufficiently visible through previous categories. These include, in particular, long-term effects on hormone systems and the environment, as well as substance properties that promote widespread and persistent distribution.

A special feature: No new GHS pictograms were introduced for these new, initially exclusively European hazard classes. Communication is carried out via hazard statements and other required labeling elements, among other things.

Endocrine Disruptors: Effect on Humans and the Environment

Endocrine disruptors are substances or mixtures that affect the hormone system and can thereby cause harmful effects.

The endocrine system controls many processes in the body, for example:

• growth,
• metabolism,
• reproduction,
• development,
• hormonal signaling pathways.

The new CLP categories distinguish between effects on human health and effects on the environment.

Category 1

This category includes substances for which an endocrine-disrupting effect is known or presumed.

Category 2

This category concerns substances for which an endocrine-disrupting effect is suspected.

Classification depends on the available scientific evidence and the respective CLP criteria. It must not be derived solely from a single test result, a general substance group designation, or an unverified database entry.

For companies, this means: substance data, harmonized classifications and supplier information must be regularly checked for updates.

PBT and vPvB substances

PBT stands for:

• persistent,
• bioaccumulative,
• toxic.

A PBT substance is difficult to degrade in the environment, can accumulate in organisms, and also has toxic properties.

vPvB stands for:

• very persistent,
• very bioaccumulative.

For these substances, the combination of very long environmental persistence and strong accumulation is particularly important.

Such properties are problematic because:

• inputs can persist over long periods,
• substances can accumulate along food chains,
• effects only become visible with a delay,
• later removal from the environment can be difficult or impossible.

The new CLP labeling makes these properties more visible within the supply chain and for users.

PMT and vPvM substances

PMT stands for:

• persistent,
• mobile,
• toxic.

vPvM stands for:

• very persistent,
• very mobile.

While for PBT and vPvB substances the focus is on bioaccumulation, for PMT and vPvM substances mobility plays a central role.

Mobile substances can spread, for example, via:

• Water,
• Soil,
• Groundwater,
• Surface waters

spread.

In combination with high persistence, this can lead to substances remaining in water cycles over long periods and being difficult to remove using conventional treatment processes.

For manufacturers and importers, the new classification means that not only acute toxicity or direct environmental effects are assessed. The long-term behavior of a substance in the environment is also gaining importance.

Which deadlines apply to substances?

Two important dates apply to substances.

Substances placed on the market for the first time from May 1, 2025

These substances must already be classified and labeled according to the new hazard classes.

This concerns products that were first placed on the EU market from this date.

Substances that were already placed on the market before May 1, 2025

For these stocks, a transitional period applies until November 1, 2026.

From this date, these substances must also meet the new requirements if they fall under the new hazard classes.

This does not mean that every older container automatically receives a new hazard label. First, it must be checked whether the classification of the specific substance is affected.

Which deadlines apply to mixtures?

Longer transitional periods apply to mixtures.

Mixtures placed on the market for the first time from May 1, 2026

From this date, they must be classified and labeled taking into account the new hazard classes.

May 1, 2026 is therefore particularly important for:

• Formulators,
• Importers of mixtures,
• Manufacturers of cleaning and process chemicals,
• Suppliers of chemical preparations,
• Companies that sell own-brand products.

Mixtures that were already on the market before May 1, 2026

For these mixtures, a transitional period applies until May 1, 2028.

Until then, products already placed on the market can continue to be made available under certain conditions according to the previous rules.

Important is the wording 'already placed on the market'. A product that was only manufactured or stored internally was not automatically made available on the market in the legal sense thereby.

In case of uncertainties, the specific flow of goods should be documented and expertly checked.

What was postponed to 2028?

The major CLP revision of 2024 contained new requirements that were originally to become mandatory in part in 2026 or 2027.

By Regulation (EU) 2025/2439, certain provisions were postponed to 1 January 2028. These include, in particular, regulations on:

• mandatory format specifications for labeling labels,
• certain requirements for advertising,
• information obligations for distance selling offers,
• certain deadlines for updating labels,
• the labeling at tank and refill stations.

This is especially important for online shops. Older information, according to which all new requirements for product pages were to become mandatory as early as 2026, may now be outdated.

The postponement does not mean, however, that no CLP obligations apply in online trade until 2028. Existing requirements for correct classification, product labeling, packaging, and hazard communication remain in place.

Who is responsible for classification and labeling?

The responsibility depends on the role within the supply chain.

CLP concerns, among others:

• Manufacturers,
• Importers,
• downstream users,
• Formulators,
• Dealers,
• certain producers and importers of articles.

Dangerous substances and mixtures must be correctly classified, labeled, and packaged before being placed on the market. So that the correct information reaches the end user, the entire supply chain must cooperate.

A dealer usually does not carry out a complete reclassification if he resells a product unchanged. However, he must ensure that labeling and packaging comply with the applicable requirements.

As soon as a company a product:

• refills,
• re-labels,
• distributes under its own brand,
• imports,
• mixes,
• changed in its composition,

significantly more extensive responsibilities can arise.

What must manufacturers and importers check?

Manufacturers and importers should at least check the following points:

Substance portfolio

Which substances and mixtures are placed on the market in the EU?

This also includes clarification of whether a product:

• a single substance,
• a substance with multiple constituents,
• a mixture,
• an article

is.

Current substance data

Is new information available on:

• endocrine-disrupting properties,
• Persistence,
• Bioaccumulation,
• Mobility,
• Toxicity?

Harmonised classification

Does a harmonised classification exist in Annex VI of the CLP Regulation?

A harmonised classification is binding for the hazard classes covered there. Other hazards must possibly be additionally assessed through self-classification.

Labeling

Do label, safety data sheet, and internal product data match?

Packaging

Does the packaging still meet the product-related requirements, for example regarding:

• leak tightness,
• material resistance,
• child-resistant closures,
• tactile hazard warnings?

Documentation

Can it be traced:

• on which data the classification is based,
• when it was checked,
• which version of the label is used,
• from which date a product was placed on the market?

What applies to formulators and downstream users?

Formulators produce mixtures from substances or other mixtures.

For them, May 1, 2026 is particularly relevant. Mixtures newly placed on the market must be evaluated based on the new hazard classes from this date.

For this, it is not sufficient to simply copy the existing label.

Among other things, the following should be checked:

• classifications of the individual components,
• concentration limits,
• available data for the entire mixture,
• transfer principles,
• interactions between components,
• new information from updated safety data sheets.

If a formulator receives an updated safety data sheet for a raw material, it should be checked whether this affects the classification of their own mixture.

A changed raw material classification does not automatically lead to a new mixture classification in every case. However, it must be assessed technically.

What obligations do distributors and online shops have?

Distributors must not rely solely on the fact that a product has been sold for years.

You should check:

• Is the product correctly labeled?
• Are the labels clearly legible?
• Do product name and product identifier match?
• Is the packaging undamaged?
• Is a current safety data sheet available, if required?
• Was a new classification from the supplier adopted?
• Are old and new product versions clearly separated in the warehouse?
• Do the shop data, product label, and documents match?

For imports from non-EU countries, the importing company regularly assumes significantly greater responsibility than a pure distributor within the EU.

Even when selling under one's own brand, it cannot be automatically assumed that the original supplier assumes all obligations for the new market presentation.

Do existing labels need to be changed immediately?

Not every label must be replaced across the board in 2026.

The decisive factors are:

• Stoff oder Gemisch,
• Datum des Inverkehrbringens,
• affected hazard class,
• existing transition period,
• possible new scientific information,
• Role of the company.

Für neu in Verkehr gebrachte Gemische gelten die neuen Gefahrenklassen ab dem 1. Mai 2026. Für bestimmte ältere Gemische besteht eine Übergangsfrist bis zum 1. Mai 2028. Bei älteren Stoffen endet die betreffende Übergangsfrist bereits am 1. November 2026.

Eine pauschale Massenänderung aller Etiketten ist daher ebenso riskant wie vollständiges Abwarten.

Sinnvoll ist eine produktbezogene Matrix mit:

• Produktname,
• Stoff oder Gemisch,
• bisherige Einstufung,
• neue Bewertung,
• Datum des Inverkehrbringens,
• Ende der Übergangsfrist,
• erforderliche Etikettenänderung,
• responsible person.

What are the effects on safety data sheets?

If the classification of a substance or mixture changes, it must be checked whether the safety data sheet also needs to be updated.

May be particularly affected:

• Section 2: Possible hazards,
• Section 3: Composition and ingredients,
• Section 11: Toxicological information,
• Section 12: Ecological information,
• Section 15: Regulatory information,
• Section 16: Changes and other information.

Operational documents may also need to be adjusted:

• Hazardous substance register,
• Risk assessment,
• Operating instructions,
• Storage concept,
• Training documents,
• Emergency measures.

A new label alone is not sufficient if internal documents continue to work with an outdated classification.

What do the changes mean for online retail?

The CLP reform fundamentally strengthens hazard communication in digital offers and distance selling. However, certain new information and format obligations have been postponed to 1 January 2028.

Nevertheless, online retailers should structure their product data now.

Important fields are:

• unique product name,
• Substance or mixture identity,
• Concentration,
• Signal word,
• Hazard pictograms,
• H-statements,
• supplementary hazard statements,
• Safety data sheet,
• responsible supplier,
• Version and update date.

Manually maintained product texts are particularly error-prone. If a label is updated, the old classification often remains visible in the shop.

A central data source is better, from which:

• Labels,
• Product pages,
• Marketplace offers,
• Safety documents,
• internal master data

be updated consistently.

Typical mistakes in implementation

Link all CLP changes to a single deadline

The new hazard classes and the comprehensive CLP reform have different deadlines.

A company must check each individual obligation separately.

Only check new products

Existing substances can also be affected after a transition period expires.

For certain older substances, 1 November 2026 is relevant.

Change the label, forget the safety data sheet

A new classification must be implemented consistently in all connected documents.

Manage product label and online shop separately

This results in contradictory hazard statements.

Adopt supplier information without verification

The supplier is an important source of information. However, your own company must check what obligations arise from its role.

Confusing import with trade within the EU

Anyone who imports a product from a third country into the EU is not just a reseller. They can be responsible as an importer for classification, labeling, and packaging.

Not documenting existing inventory

Without a traceable date of placing on the market, it is difficult to assess whether a transition period can be used.

Equating new hazard classes with new pictograms

The new EU hazard classes currently do not have their own additional GHS pictograms.

Using outdated summaries

The application dates of certain regulations were changed again at the end of 2025. Information material from 2024 or the first half of 2025 may therefore no longer be current for individual deadlines.

Practical CLP checklist for companies

Check for each product:

• Is it a substance or a mixture?
• What role does your company have: manufacturer, importer, formulator, or distributor?
• When was the product first placed on the market?
• Is a transition period applicable?
• Have the new hazard classes been checked?
• Are current data on endocrine disruption available?
• Have PBT, vPvB, PMT and vPvM properties been assessed?
• Is there a harmonized classification?
• Do the label and safety data sheet match?
• Are the H and P statements current?
• Is the safety data sheet available in the required language?
• Does the hazardous substance register need to be updated?
• Does the risk assessment need to be adjusted?
• Are old and new label versions separated in the warehouse?
• Do the product data in the online shop match the container?
• Are all changes and review decisions documented?
• Has a responsible person been appointed for implementation?

2026 is not a year in which all CLP requirements are rewritten simultaneously. But it is a decisive year for the new hazard classes.

For mixtures placed on the market anew, these apply from May 1, 2026. For certain older substances, the transition period ends on November 1, 2026. At the same time, selected new requirements for labels, advertising, and distance selling have been postponed to January 1, 2028.

Companies should therefore not start with a blanket labeling action. The better approach is a structured product review: capture the portfolio, clarify roles, assign deadlines, check classification, and update all communication channels synchronously.

At ChemMarkt.de you will find chemical reagents and technical raw materials with detailed product information. When selecting and using them, always observe the current labeling and the product-specific safety data sheet.

Discover chemical reagents and technical raw materials at ChemMarkt.de.