HCPC Brands EuropeThe CLP Labelling Amendment (EU) 2024/2865
Regulation (EU) 2024/2865 of 23 October 2024 introduces the most significant update to CLP labelling since the original regulation - responding to the growth of cross-border online sales of chemical products and the need for clearer, more consistent hazard communication. Published 20 November 2024 and in force since 10 December 2024, its most consequential provisions were originally due to apply from mid-2026, but have since been postponed.
The Postponement - What Changed
In December 2025, Regulation (EU) 2025/2439 postponed a designated set of the 2024/2865 deadlines by 12 or 18 months, depending on the provision - 18 months for those originally due on 1 July 2026 and 12 months for those due on 1 January 2027 - unifying them at 1 January 2028. Provisions outside that set kept their original dates, including the EU-established supplier requirement, which has applied since 1 July 2026. This matters in practice because a significant amount of third-party guidance published in 2024 and 2025 still cites the original, now-superseded dates - worth double-checking the source date whenever encountering a "1 July 2026" or "1 January 2027" CLP deadline reference.
| Provision | Original deadline | Current deadline |
|---|---|---|
| Article 30 - relabelling deadlines | 1 July 2026 / 1 January 2027 | 1 January 2028 |
| Article 31(3) - mandatory label format (font size, spacing) | 1 January 2027 | 1 January 2028 |
| Article 48 - advertising information requirements | 1 July 2026 | 1 January 2028 |
| Article 48a - distance selling requirements | 1 July 2026 | 1 January 2028 |
| Annex II - fuel dispenser labelling | 1 July 2026 | 1 January 2028 |
| Article 4 - supplier established in the Union | 1 July 2026 | Not postponed - applies since 1 July 2026 |
Core New Requirements
- Physical EU address — the label of a hazardous product must show a physical address within the EU for the party responsible for CLP compliance, to speed up emergency traceability. Separately, the requirement introduced into Article 4(11) of Regulation (EC) No 1272/2008 (CLP), as amended, that a supplier established in the Union be responsible for compliance was not postponed: it has applied since 1 July 2026.
- Label format rules — minimum font size and line spacing requirements. Table 1.3 of Annex I sets the minimum font size as an x-height: 1,2 mm for packaging not exceeding 0,5 litres, 1,4 mm above 0,5 up to 3 litres, 1,8 mm above 3 up to 50 litres, and 2,0 mm above that. Line spacing must be at least 120% of the font size. These apply from 1 January 2028 and are likely to require packaging and mould redesigns for many products.
- Advertising information — advertisements for hazardous products, including online advertising, must carry defined hazard information.
- Distance selling — Article 48a applies to distance offers of substances and mixtures, not only to offers to consumers. Such an offer must show the label elements required by Article 17 clearly and visibly, before the purchase is completed and not only on the product once delivered.
- Fuel dispenser labelling — new labelling requirements apply at fuel stations, reflecting the regulation's broader scope beyond traditional packaged consumer products.
Why This Was Postponed
The postponement forms part of the European Commission's wider "Omnibus" simplification initiative - specifically the European Chemicals Industry Action Plan published in July 2025 - aimed at reducing administrative burden and compliance costs across the chemical and cosmetics sectors, while explicitly stating that the underlying scientific and safety assessment obligations of CLP remain unaffected and on schedule. Only the administrative, labelling-format, and sales-channel provisions were pushed back.
A Note on This Timeline
Given these deadlines have already moved once, 1 January 2028 is the currently adopted application date for these provisions. Prepare for that date. We monitor developments on this regulation and will update this page if the legislation changes.
Sources
Regulation (EU) 2024/2865 of the European Parliament and of the Council of 23 October 2024, amending Regulation (EC) No 1272/2008 (CLP). Regulation (EU) 2025/2439, amending the dates of application and transitional provisions.
Frequently Asked Questions
What is the current deadline for the new CLP labelling requirements?
1 January 2028 for the label format, advertising, distance-selling, and fuel-station labelling provisions. This is a postponed date - the original deadlines set by Regulation (EU) 2024/2865 were 1 July 2026 and 1 January 2027, before Regulation (EU) 2025/2439 unified them to 2028.
Why were the original CLP deadlines postponed?
The European Commission cited the need to reduce administrative burden and cost for companies while maintaining a high level of protection for human health and the environment, and to align the CLP timeline with parallel amendments to the fertilising products and cosmetics regulations.
Does a hazardous product label now need a physical EU address?
Yes. Regulation (EU) 2024/2865 requires the label of a hazardous chemical product to include a physical address within the European Union for the supplier responsible for CLP compliance, intended to make products and their responsible parties easier to trace in an emergency.
What changes for online/distance sales of hazardous chemicals?
Article 48a covers distance offers of substances and mixtures - not only offers to consumers. Such an offer must show the label elements required by Article 17 clearly and visibly, rather than leaving hazard information on the physical product a buyer receives after purchase. Until those rules apply, the existing advertising obligations of Article 48 continue to apply to advertisements.
Should I wait until 2028 to prepare for these changes?
No - and for part of the amendment, waiting is not an option. The postponement to 1 January 2028 covers a designated set of provisions: label format, advertising, distance selling and fuel-station labelling. Other provisions of Regulation (EU) 2024/2865 kept their original application dates, including the requirement introduced into Article 4(11) of Regulation (EC) No 1272/2008 (CLP), as amended, that there be a supplier established in the Union responsible for compliance, which has applied since 1 July 2026. Those obligations are already in force today.
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