Omnibus VI Package: European Parliament and Council Reach a Provisional Agreement

On 17 June, the European Parliament and the Council reached a provisional agreement on the Commission's draft Regulation, which, as part of the Omnibus VI package, proposed revisions to the CLP Regulation, the Cosmetics Regulation and the Fertilising Products Regulation with the aim of simplifying selected provisions and reducing the administrative burden on businesses.

The agreed measures address some of the most widely debated aspects of the reform, including label readability, the use of digital tools, advertising and distance sales, the deadlines for updating classifications, and the dates of application of the new provisions, while maintaining consumer protection as the overarching objective.

The following sections provide an overview of the main changes concerning the CLP Regulation (Regulation (EC) No 1272/2008).

• Label readability: For substances and mixtures intended for the general public, the label text will be required to use a font with an x-height of at least 1.2 mm. For packages with a capacity of less than 125 ml, a minimum x-height of 0.9 mm will be permitted. This provision is intended to ensure more consistent and effective communication of hazard information by introducing more specific technical requirements, thereby addressing the implementation uncertainties that emerged during the legislative negotiations.
  
  
• Digitalisation of labelling information: The agreement introduces greater flexibility for small packaging. For packages with a capacity of 10 ml or less, certain label elements may be provided in a digital format, provided that the hazard pictograms continue to appear physically on the outer packaging. This solution represents a balanced approach between the need to address the apparent space limits of very small packages and the objective of ensuring that essential hazard information remains immediately accessible to users.
  
  
• Advertising and distance sales (Articles 48 and 48a): The provisional agreement further simplifies the information requirements. In particular, advertisements directed at the general public will continue to be required to include the statement "Always read the label and product information before use", while the obligation to display hazard pictograms and the signal word will be removed. In addition, advertising addressed exclusively to professional users will fall outside the scope of these requirements, provided that it is not accessible to the general public. With regard to distance sales, the CLP label elements must remain clearly visible before the purchase is completed. This obligation will also apply to offers formally addressed to professional users where consumers are nevertheless able to conclude the purchase.
  
  
• Revised deadlines for updating classification and labelling: Unlike the Commission's original proposal, which required suppliers to update the classification and labelling without undue delay whenever a new assessment resulted in a more strict classification of a substance or mixture, the provisional agreement introduces a fixed deadline of 15 months. Establishing a clear timeframe is intended to enhance legal certainty and promote a more consistent application of the legislation by both economic operators and competent authorities.

Finally, the agreement confirms that the application of most of the new provisions of the CLP Regulation will be aligned with 1 January 2028, in line with the "Stop-the-Clock" program. This measure is intended to prevent a fragmented implementation of the legislation and to provide companies with sufficient time to adapt their processes, labelling and information systems ahead of the application of the new regulatory framework.

The Omnibus VI package will also have a significant impact on the Cosmetics Regulation (Regulation (EC) No 1223/2009) and the Fertilising products Regulation (Regulation (EU) 2019/1009).

With regard to Cosmetics, the co-legislators agreed to substantially accelerate the phase-out of CMR substances (carcinogenic, mutagenic or toxic for reproduction). Unless a derogation applies, the transition periods for withdrawing affected products from the market will be reduced compared with the Commission's original proposal, giving companies 6 months to cease placing products on the market and 12 months to exhaust existing stocks. Where companies intend to apply for a derogation, they will have up to 12 months from the date of the new CLP classification to submit their application. If the derogation is refused on safety reasons, significantly shorter transition periods will apply, namely 3 months for placing products on the market and 9 months for making them available on the market. The agreement also rejects exemptions for CMR substances based on the route of exposure (oral or inhalation) and reinstates the requirement for prior notification of cosmetic products containing nanomaterials. To support the substitution of hazardous substances, the Commission will publish dedicated guidance on alternatives assessment within one year of the Regulation's entry into force.

With regard to fertilising products, the agreed measures introduce substantial simplifications to the chemical requirements, particularly for products derived from circular economy processes or complex feedstocks. In particular, the REACH registration requirements applicable to Component Material Categories (CMCs) will be simplified through a reduction of formal requirements and administrative burdens for standardised chemical substances used in the sector. More broadly, one of the common themes across all three legislative acts covered by the Omnibus VI package is the promotion of digital labelling. For fertilising products, whose labels are often particularly dense with technical information and instructions for use, the new provisions will also facilitate the digitalisation of more detailed instructions and non-critical chemical safety information, thereby simplifying the physical label while preserving access to essential information.

The political agreement must now be formally endorsed by both the Council and the European Parliament. The final text will then be formally adopted and published in the Official Journal of the European Union. At the moment, the European Parliament's plenary vote is expected to take place in October. Subject to confirmation of the legislative timetable and the absence of further delays, publication in the Official Journal is expected by the end of 2026.