CLP Regulation: proposal to postpone some deadlines and simplify obligations introduced by Reg. (EU) 2024/2865

On 8 July 2025, the European Commission presented a long-awaited and substantial package of legislative proposals, still in draft stage, aimed at redesigning some of the most burdensome obligations for the chemical industry. Through two distinct acts, identified as COM(2025) 526 final and COM(2025) 531 final, Brussels intends, on the one hand, to postpone the application of certain key provisions of the recent update to the CLP Regulation (Reg. EU 2024/2865), and on the other hand, to substantially simplify its content.

The initiative, which would also amend the regulations on cosmetic products and fertilising products, represents a direct response to the growing concerns of the industrial sector regarding increasing regulatory responsibilities.

Proposal 1: “Stop the Clock” on Upcoming Deadlines (COM/2025/526)
The first and most urgent proposal aims to provide “legal certainty” to companies by postponing the entry into force of some of the most impactful provisions introduced by Regulation (EU) 2024/2865, which amended the CLP. Many of these rules were set to become mandatory between 2026 and 2027, but these are same provisions the Commission now intends to simplify with the second proposal.

To prevent companies from having to comply with rules that are about to change, the Commission proposes to postpone the application date of the following provisions to 1 January 2028:

• Mandatory label format requirements (e.g. minimum font size and line spacing).
• New rules on advertising and remote sales.
• The fixed six-month deadline for updating labels following a change in classification.
• Rules for the labelling of fuel distributors.

This provision effectively “freezes” the implementation of the most controversial obligations, allowing Parliament and Council time to approve the simplification package and enabling companies to prepare for a single, definitive set of rules.

Proposal 2: Substantial Simplification for Labelling and Advertising (COM/2025/531 and Annexes)
The core of the revision is contained in the second proposal, which directly amends the text of the CLP Regulation to ease obligations while maintaining a high level of protection for health and the environment. The main changes, detailed in the technical annexes, are as follows:

1. More Flexible Label Format:
   Requirements on minimum font size, line spacing and label features (“black print on white background”) introduced by Reg. (EU) 2024/2865 are removed.
2. Introduction of Mandatory “Digital Contact”:
   One of the most significant innovations is the replacement of traditional telephone contacts with a mandatory “digital contact” on the label (together with name and address). The objective is to modernise and streamline communication between suppliers, enforcement authorities and end users.
3. Simplified Rules for Advertising and Distance Sales:
   The new rules on advertising and distance sales are drastically streamlined. Information obligations will apply only to products intended for the general public, excluding business-to-business (B2B) transactions, which are already covered by obligations under Safety Data Sheets (SDS). Furthermore, advertisements will no longer need to display pictograms, signal words and all hazard statements. Instead, it will suffice to include the phrase: “Always read the label and product information before use.”
4. Label Updates without Fixed Deadlines:
   The fixed six-month deadline for label updates is removed. It will be replaced with the more flexible requirement, already present in the previous version of CLP, to update labels “without undue delay.” This change acknowledges the complexity of supply chains and production cycles.
5. More space for Digital Labelling:
   The proposal expands the possibilities offered by digital labels. In particular, where more than one supplier is listed on a physical label, the contact details of the other suppliers (in addition to the main one) may be provided exclusively via the digital label, freeing up valuable space on packaging.
6. Simplifications for Small Packaging and Fuels:
   For containers < 10 ml, derogations for labelling small packaging are clarified and simplified, making it easier for companies to understand which information may be omitted.
   For fuel distributors, it is also clarified that it is not necessary to display the Unique Formula Identifier (UFI) on the dispenser pump.
7. Transitional Periods for Stock Depletion:
   Substances and mixtures placed on the market before 1 January 2027 may be sold until 1 January 2029. In practice, companies will have one additional year to deplete stocks, compared to the deadline set by Regulation (EU) 2024/2865.

At this step, these are only proposals, but the message is clear: Europe is trying to listen to industry’s needs and adjust its course. We now have to wait for the next steps to see which direction the legislative process will take.