The European Union’s transitional period for new hazard classifications under its CLP framework is drawing to a close, with a critical deadline fast approaching for businesses operating in the chemical supply chain.
Introduced by EU Commission Delegated Regulation (EU) 2023/707, the new hazard classes cover endocrine disruption for human health and the environment, as well as very persistent, very mobile substances, known as vPvM.
For substances already placed on the EU market and in the supply chain before 1 May 2025, the final transition deadline is 1 November 2026.
From that date, all substances must be classified and labelled in full accordance with the newly established hazard classes, leaving no room for legacy exceptions.
Companies that placed substances on the market for the first time from 1 May 2025 have already been subject to the new classification rules from that date forward.
The approaching deadline carries significant implications not only for labelling but also for Registration, Evaluation, Authorisation and Restriction of Chemicals, commonly referred to as REACH, registration dossiers.
The European Chemicals Agency, ECHA, has made clear that after the applicable transition period, it will be mandatory to indicate whether a substance is classified under any of the new hazard classes.
ECHA also provides specific guidance on updating REACH registrations where the self-classification of a substance changes, underlining the administrative burden businesses may need to address promptly.
Critically, ECHA states that where a substance does not meet the criteria for a new hazard class, the reasons for that conclusion should be included in the registration dossier, adding a documentation requirement even for substances deemed non-hazardous under the new rules.
ECHA’s IUCLID validation rules further confirm that the current default entry of “hazard class not assessed” will not be accepted after the applicable transition period expires.
Businesses across the chemical sector are urged to review their existing dossiers, self-classifications, and labelling practices well in advance of the November 2026 cutoff to avoid compliance failures.
The convergence of labelling, registration, and notification requirements means that companies face a multifaceted compliance challenge that demands both scientific assessment and careful documentation.
With less than a year remaining before the deadline takes full effect, chemical manufacturers, importers, and downstream users operating within the EU market should treat this as an immediate operational priority.