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The EU Classification, labeling and Packaging (EU CLP Regulation) is regularly updated through Adaptations to Technical Progress (ATPs). These updates introduce new or revised harmonised classifications for substances, directly affecting how products are classified, labelled, and documented in the EU.
Several CLP ATPs have mandatory application dates in 2026, making early preparation critical for companies placing substances or mixtures on the EU market, especially for non-EU manufacturers exporting to the EU.
Key CLP ATP Deadline in 2026
The 22nd ATP CLP harmonised classification, updating CLP Annex VI (harmonised classifications) of the CLP Regulation, will apply from 1 May 2026. This means that:
- New and amended harmonised classifications listed in the ATP must be applied by this date
- Suppliers are responsible for labeling updates and comprehensive Safety Data Sheet (SDS) updating for affected substances and mixtures
- Substances and mixtures placed on the market from 1 May 2026 onwards must reflect these updated CLP classifications, labeling, and hazard information in documentation and packaging
Companies can voluntarily adopt the updated classifications before this date, but 1 May 2026 is the official deadline for mandatory CLP compliance.
Other Ongoing CLP Developments
Draft and Upcoming ATPs
- The EU has notified the WTO of a draft ATP proposing new and revised harmonised classifications for additional substances (potential future ATP) with adoption expected after consultation in early 2026.
Future Harmonised Classifications
- The 23rd ATP has been adopted and will apply from 1 February 2027. Although not a 2026 deadline, companies should begin planning now.
Core Requirements and Obligations Under EU CLP Regulation
Companies placing substances or mixtures on the EU market must meet the following key obligations:
1. Classification
- Classify substances and mixtures according to the latest CLP criteria
- Apply mandatory harmonised classifications from CLP Annex VI
2. Labeling
- Update labels to include:
- Correct hazard pictograms
- Signal words
- Hazard (H) and precautionary (P) statements
- Ensure labels are legible, durable, and comply with EU language requirements
3. Packaging
- Use packaging that prevents leakage and meets CLP safety requirements
4. CLP Safety Data Sheet (SDS)
- Revise SDSs to reflect updated CLP classification and hazard information
- Provide SDSs in the official language(s) of each EU Member State where the product is marketed
5. Classification & Labeling Notification
- Update or submit Classification & labeling notifications to the European Chemicals Agency (ECHA) when classifications change
- Share updated information down the supply chain promptly
Who Is Impacted by the 2026 Deadline?
- EU manufacturers and formulators
- EU importers
- Non-EU manufacturers exporting to the EU (via importers or Only Representatives)
For companies outside the EU exporting into the bloc, ensuring compliant SDSs and meeting CLP labeling requirements, reflecting harmonised classifications by 1 May 2026, is essential for continued market access.
Why Early Preparation Matters
Missing the 1 May 2026 deadline can lead to:
- Shipment delays or border holds
- Market withdrawals or enforcement actions
- Increased Regulatory risk and compliance costs
Proactive impact assessments allow companies to align classification, labeling, and SDS updates well ahead of the application date.
Keeping pace with CLP ATP deadlines, especially harmonised classification updates that take effect from 1 May 2026, can be complex. Freyr’s experts support companies with ATP impact assessments, CLP safety data sheet (SDS) and label updates, and Classification & labeling notification strategies, ensuring CLP compliance and uninterrupted EU market access. Want help preparing for the 2026 CLP ATP deadline? Reach out to Freyr for tailored support.
