Upcoming CLP Deadline: Potential Impact on REACH Dossier Updates
31 January 2025
The Delegated Regulation on CLP, (EU) 2024/197, amending Regulation (EC) 1272/2008 and enforced since April 2023, introduced new hazard classes:
- Endocrine disruption for human health, Category 1 and 2
- Endocrine disruption for the environment, Category 1 and 2
- PBT (persistent, bioaccumulative and toxic) and vPvB (very persistent and very bioaccumulative)
- PMT (persistent, mobile and toxic) and vPvM (very persistent and very mobile).
The new requirements apply to substances placed on the market for the first time on or after 1 May 2025, including new quantities of substances already on the market before that cut-off date. Substances that were placed on the market before 1 May 2025, and are already in the supply chain, do not need to be reclassified or relabelled until 1 November 2026.
From 1 May 2026 at the latest, mixtures that are placed on the market for the first time, including new quantities of mixtures already on the market before that date, must comply with the new rules. Mixtures that were placed on the market before 1 May 2026, and are already in the supply chain, are not required to be reclassified or relabelled until 1 May 2028.
In case of changes in the classification and labeling of the registered substance due to the new hazard classes, the REACH registration dossier must be updated within 6 months from the date when the decision to change the substance's classification and labelling was taken (Regulation (EC) No 1907/2006, Art. 22(1) and Commission Implementing Regulation (EU) 2020/1435). This includes the CSR update and the reevaluation of the CSA. Changes to the classification and labelling of the registered substance should be communicated in the SDS.
Contact our experts if you need help assessing the endocrine disruptive (ED), persistent, mobile or bioaccumulative properties of your substances and mixtures.