CLP · Legislative changes
CLP changes under Regulation 2024/2865
When planning for CLP changes, businesses need to distinguish the adopted postponement of certain requirements from the broader simplifications under Omnibus VI. An announced change does not mean that existing obligations no longer apply.
Status reviewed on 5 November 2026. This article addresses COM(2025) 526 and COM(2025) 531 in connection with Regulation 2024/2865.
Why is the revised regulation being amended?
Regulation (EU) 2024/2865 amended the CLP Regulation – Regulation (EC) No 1272/2008. It addresses, among other matters, labelling, online sales, advertising and information for emergency health response. In July 2025, the Commission proposed two related measures: postponing certain application dates and simplifying a wider range of requirements for chemical products.
The term “correction” can therefore be misleading. This is a legislative amendment to requirements or deadlines, rather than simply the correction of a typographical error. To make a practical decision, a business needs to identify the legal act and the specific provision being amended.
The postponement of certain requirements has been adopted
Regulation (EU) 2025/2439, adopted on 26 November 2025 and in force since 23 December 2025, has already amended Regulation 2024/2865. It sets 1 January 2028 as the application date for certain requirements concerning label updates, advertising, distance sales, label formatting and labelling at refill stations.
This is not a blanket postponement of the entire CLP revision. Other provisions have their own application dates and transitional conditions. The postponement also does not remove the obligation to classify, label and package products correctly under the CLP rules currently in force.
What does the broader simplification proposal cover?
In addition to CLP, proposal COM(2025) 531 covers cosmetic products and fertilising products. On 17 June 2026, the Council of the EU announced a provisional agreement with the European Parliament. For CLP, it addresses, among other matters, label readability for business-to-business sales and sales to the general public, certain exemptions for small packaging and the time allowed for updating labels. The agreement also refers to 1 January 2030.
An announcement of a provisional agreement is different from a finally adopted and published legal act. This article therefore does not present 2030 as a generally applicable deadline for all CLP requirements. Before relying on a new date, check the final text, its publication in the Official Journal of the EU and the scope of the specific provision.
What should businesses do now?
BiSafe recommends organising your implementation plan by individual obligation. For each one, record the applicable provision, application date, any transitional period and the products affected.
- Distinguish binding requirements from proposals and provisional agreements.
- Review labels, packaging sizes and sales channels.
- Check online product offers and advertising materials.
- Assess UFI/PCN obligations separately; postponing certain label rules does not automatically postpone notifications.
- Check the applicable legal text again before a major packaging reprint.
This review helps you plan changes without unnecessary reprints and avoid delaying obligations that already apply. A news headline about a “CLP postponement” is not sufficient to assess an individual product.
Need to assess the impact on your products?
Send your label, product details and sales channels to info@bisafe.si. We can help identify the relevant changes. For related obligations, see our UFI and PCN notification services.
