What changed, and which rules apply?
Commission Delegated Regulation (EU) 2023/707 added criteria and label elements to Annex I of the Classification, Labelling and Packaging (CLP) Regulation. It entered into force on 20 April 2023, with later mandatory application dates.
CLP communicates hazards of substances and mixtures supplied in the EU, subject to its scope and exemptions. Manufacturers, importers, downstream users and distributors have duties according to their roles. Read ECHA’s explanation of CLP alongside the applicable legal text.
The new hazard groups
- ED HH: endocrine disruption for human health, categories 1 and 2.
- ED ENV: endocrine disruption for the environment, categories 1 and 2.
- PBT / vPvB: persistent, bioaccumulative and toxic; or very persistent and very bioaccumulative.
- PMT / vPvM: persistent, mobile and toxic; or very persistent and very mobile.
The endocrine categories distinguish known or presumed disruption from suspected disruption. For the persistence groups, classification requires assessment of the relevant criteria and evidence. A substance’s identity or a supplier’s informal description does not establish the result.
The corresponding EU hazard-statement codes are EUH380/381, EUH430/431, EUH440/441 and EUH450/451. Check the prescribed label elements for the actual classification using ECHA’s new hazard class resources. Other applicable CLP hazards still need assessment.
Substances and mixtures have different deadlines
The 2023/707 transitional provisions distinguish quantities already placed on the market from subsequent supply:
| Product | Ordinary application | Compliance date for earlier stock |
|---|---|---|
| Substances | 1 May 2025 | Placed on the market before 1 May 2025: 1 November 2026 |
| Mixtures | 1 May 2026 | Placed on the market before 1 May 2026: 1 May 2028 |
As at 12 October 2026, the substance stock deadline is approaching; the ordinary mixture deadline has passed. A product name existing before the cutoff does not extend the transition to new quantities first placed on the market after the cutoff. Check that earlier stock remains unchanged, and keep evidence of the relevant market dates.
Later CLP amendments have their own timetables
Regulation (EU) 2024/2865 revised other CLP classification, labelling and packaging provisions. Regulation (EU) 2025/2439 moved the application of certain provisions introduced by that revision to 1 January 2028. This is a partial postponement. It does not change the new hazard class deadlines under Regulation 2023/707 shown above.
Check the particular provision before planning a label or packaging change. Some requirements of the 2024 revision already apply, and the timing differs between obligations. An announcement about postponement does not establish which deadline applies to a particular product or supply arrangement.
CLP hazards and ADR transport classification
A CLP classification does not automatically assign an ADR UN number, transport class or packing group. Transport classification follows the rules for the transport mode and the particular goods. CLP Article 1(6) excludes dangerous goods transport from its general scope, while Article 33 addresses the interaction of supply and transport labels on packaging. Consult the CLP text.
Review SDS Section 2 and Section 14 separately. Neither a new EUH statement nor the absence of an ADR classification establishes safe handling or an exemption. Resolve inconsistent product and shipment information before the operation.
A practical review for your business
Identify the products, supplier roles, batches and market dates affected. Gather the current composition, classification assessment, label, SDS and relevant supplier correspondence. Record which amendment applies, what remains uncertain and who will resolve it.
Use the current ECHA CLP guidance to support a competent assessment. Review related supplier information and workplace arrangements when hazards change. ECHA explains the need to update safety data sheets when relevant new hazard or risk-management information becomes available.
For DGSA support with dangerous goods transport in Spain, provide the product documents, quantities, packaging, transport modes and activities involved. Contact DGSA to discuss the scope of the review.