A chemical bottle displays the product name, H-statements, P-statements, signal word and several hazard symbols. On another product, however, a pictogram is missing even though a new hazard class is indicated. At the same time, dates such as 1 May, 1 July and 1 November 2026 are appearing.

Anyone who manufactures, imports, distributes or uses chemicals professionally must therefore take a closer look in 2026.

After all, behind the term “CLP 2026” there are several different changes: new European hazard classes, new transitional periods and further amendments to the CLP Regulation. Some obligations already apply. Others were later postponed to 2027 or even 2028.

This guide shows which CLP rules are actually relevant in 2026, what is changing in the classification and labelling of substances and mixtures, and which deadlines companies should keep in mind.

Table of contents

What does the CLP Regulation govern?

CLP stands for:

Classification, Labelling and Packaging

So:

Classification, labelling and packaging of substances and mixtures.

The European CLP Regulation is Regulation (EC) No 1272/2008.

It lays down how chemical hazards are identified and communicated within the European Union.

A chemical product may, for example, be classified as:

• flammable,
• acutely toxic,
• corrosive,
• irritating to the skin,
• damaging to the eyes,
• carcinogenic,
• toxic to reproduction,
• hazardous to the aquatic environment.

The required labelling elements are then derived from the classification.

Depending on the product, these include, among other things:

• hazard pictograms,
• signal word,
• H statements,
• P statements,
• additional EUH statements.

The CLP Regulation applies directly in the EU member states. Manufacturers, importers, downstream users and distributors have different obligations depending on their role.

Why is 2026 particularly important for CLP?

Several deadlines coincide in 2026.

The most important are two developments:

First: The new European hazard classes introduced as early as 2023 are reaching further binding application dates.

Second: Parts of the major CLP reform under Regulation (EU) 2024/2865 apply from 1 July 2026.

At the same time, some of the obligations originally planned to apply earlier were postponed again by Regulation (EU) 2025/2439.

That is exactly what causes confusion.

An older overview from 2024 or early 2025 can therefore contain application dates that are now incorrect. The current consolidated rules provide for staggered dates on 1 July 2026, 1 January 2027 and 1 January 2028.

Two different CLP amendments should not be confused.

When it comes to “CLP 2026”, two legislative amendments are often confused.

Regulation (EU) 2023/707

This amendment introduced new hazard classes into the European CLP system.

It concerns in particular:

• endocrine-disrupting properties,
• Persistence,
• Bioaccumulation,
• Mobility,
• Toxicity.

The Regulation entered into force as early as 2023, but has staggered transition periods.

This is why 1 May 2026 and 1 November 2026 are particularly important dates.

Regulation (EU) 2024/2865

The second major reform affects considerably more areas of the CLP Regulation.

These include, among other things, changes to:

• classification,
• Labelling,
• Packaging,
• Online retail information,
• Labels,
• Updating obligations,
• Notifications.

It entered into force on 10 December 2024, albeit with different application dates.

In 2025, some of them were postponed again.

For companies, therefore, the question is enough:

“Does the new CLP already apply?”

not enough.

The right question is:

“Which specific CLP provision applies to this product, and from what date does it apply?”

What are the new hazard classes?

Additional hazard classes were introduced with Delegated Regulation (EU) 2023/707.

In particular, BAuA and ECHA distinguish the following:

ED HH

Endocrine disruption for human health.

ED ENV

Endocrine disruption for the environment.

PBT

Persistent, bioaccumulative and toxic.

vPvB

Very persistent and very bioaccumulative.

PMT

Persistent, mobile and toxic.

vPvM

Very persistent and very mobile.

In doing so, CLP extends the consideration of chemicals to include properties that partly go beyond classic acute hazards.

It is not just about that:

“Does a substance directly cause corrosion?”

but also, for example:

“Does it remain in the environment for a very long time and is it at the same time particularly mobile?”

Endocrine disruptors: new classification for humans and the environment

Endocrine disruptors are substances that can influence the hormone system and can thereby cause adverse health effects in humans or organisms in the environment.

In doing so, CLP distinguishes separate hazard classes for:

• human health,
• Environment.

In addition, categories exist according to the evidence for endocrine-disrupting properties.

This makes it possible to communicate a corresponding hazard directly within the CLP system in the future.

For companies, this means:

A substance that has so far been assessed according to the classic CLP criteria may receive additional classification elements on the basis of the new criteria.

This can subsequently have an impact on:

• Label,
• Safety data sheet,
• internal hazardous substance documentation,
• Risk assessment,
• Purchasing and substitution.

PBT and vPvB: persistent, bioaccumulative and toxic

PBT stands for:

persistent – bioaccumulative – toxic.

Such a substance possesses several problematic properties at the same time.

Persistent

It is degraded only slowly in the environment.

Bioaccumulative

It can accumulate in organisms or in food chains.

Toxic

It possesses relevant toxic properties.

The category vPvB describes substances that:

• very persistent,
• very bioaccumulative

are.

The long-term relevance is obvious:

A substance does not have to directly cause visible damage in order to pose a significant environmental problem in the long term.

PMT and vPvM: particularly mobile substances in focus

PMT stands for:

persistent – mobile – toxic.

vPvM means:

very persistent – very mobile.

Here, in addition to persistence, the mobility of a substance in the environment plays a particularly important role.

A mobile substance can spread, for example, via water pathways.

This is particularly relevant for:

• Groundwater,
• Surface waters,
• Drinking water resources.

It is precisely this combination of persistence and mobility that has received significantly more regulatory attention in recent years.

With the inclusion of PMT and vPvM, this hazard profile can now be explicitly taken into account within the European CLP system.

Why are there no new pictograms for the new hazard classes?

Anyone who hears about new hazard classes may also expect new red-bordered hazard symbols.

There are none yet.

BAuA explains why:

The additional hazard classes were initially introduced at the European level and are not yet part of the United Nations' Globally Harmonized System – the UN-GHS.

Therefore, there are currently no corresponding new GHS hazard pictograms for these new European classes.

This is important in practice.

The absence of a new hazard pictogram on the label does not automatically mean that the product's CLP classification has not changed.

H and P statements and other labelling elements must therefore always be checked against the current classification.

Which CLP deadlines apply to substances in 2026?

For substances, there are two situations with regard to the new hazard classes.

Substances that were newly placed on the EU market on or after 1 May 2025

The new hazard classes already apply to them.

They must be classified according to the new criteria and labelled where required.

Substances that were already on the EU market before 1 May 2025

A transitional period applies here.

Quantities already in the supply chain must comply from:

1 November 2026

meet the new requirements.

This date is particularly relevant for businesses with older stock.

In September or October 2026, it will therefore no longer be sufficient to check only:

“When did we buy this bottle?”

It is also important:

• Which classification currently applies?
• Does a new hazard class apply to this substance?
• Is the label still up to date?
• Is there a new version of the safety data sheet?
• Which transitional rule does the specific stock fall under?

Which CLP deadlines apply to mixtures in 2026?

Different transitional periods apply to mixtures.

New mixtures from 1 May 2026

Mixtures placed on the EU market on or after this date must already take the new hazard classes into account.

Mixtures already marketed before that date

Mixtures that were already on the EU market before 1 May 2026 and are in the supply chain have a longer transitional period.

In principle, they must comply from:

1 May 2028

meet the new requirements.

This gives rise to an important distinction in 2026:

Substance or mixture?

There is no one-size-fits-all CLP deadline for all chemicals.

What does 'placed on the market' mean?

This term is decisive for transitional periods.

In European chemicals law, 'placing on the market' does not simply mean:

The customer has already used the product.

Rather, what is decisive is the making available or supply within the supply chain in accordance with the legal definition.

ECHA illustrates the transitional rule with examples:

A mixture that was already on the market before 1 May 2026 and is in the supply chain may fall under the transitional period.

If, on the other hand, a new quantity of the same mixture is produced after this date and placed on the market anew, the current rules must already be taken into account for this new quantity.

The production date alone therefore does not always answer this question.

Companies with critical inventories should maintain traceable documentation:

• Batch,
• Supplier,
• Date of supply,
• applicable classification,
• Label version.

What applies as of 1 July 2026?

The second important change comes from the comprehensive CLP reform introduced by Regulation (EU) 2024/2865.

Some of its provisions apply as of:

1 July 2026

to be applied on a mandatory basis.

The current rules also contain transitional provisions for products that had already been placed on the market previously. Stocks that, before 1 July 2026, were classified, labelled and packaged in accordance with the previous regulations and were already on the market may, in principle, fall under the transitional rule for the affected provisions until 1 July 2028.

The changes relevant as of July 2026 include, among other things, a more precise requirement for supplier information on the label.

In addition, as of July 2026, the names of companies that have submitted active classification and labelling notifications will in principle be published in the C&L Inventory.

For a pure laboratory user, this publication may be of little relevance.

For:

• Manufacturers,
• Importers,
• Registrants,
• Suppliers

it can, however, be directly important.

What information is still required on a CLP label?

The basic principle of labelling remains in place.

If a substance or mixture is classified as hazardous and CLP requires labelling, the label continues to contain, depending on the product, among other things:

• supplier information,
• product identifier,
• for consumer products, where applicable, the nominal quantity,
• hazard pictograms,
• signal word,
• hazard statements,
• precautionary statements,
• required supplementary information.

ECHA continues to list these elements as central components of a CLP label.

H-statements

H stands for:

Hazard statement – hazard warning.

Example:

H302 – Harmful if swallowed.

P-statements

P stands for:

Precautionary statement – safety instruction.

Example:

P280 – Wear protective gloves/protective clothing/eye protection/face protection.

Signal word

Depending on the severity of the hazard profile, for example:

Danger

or

Warning

are used.

Hazard symbols

The familiar red-bordered diamonds visualise certain hazard classes.

A label is therefore not a decorative part of the packaging.

It is an essential instrument of hazard communication.

Supplier on the label: What has changed?

One of the changes relevant as of 1 July 2026 concerns supplier information.

ECHA now explicitly states in the requirements for the CLP label that the listed supplier must be based or established in the EU.

Accordingly, the following belong on the label:

• Name,
• Address,
• Telephone number

of the relevant supplier.

This is particularly important for:

• Imports from third countries,
• international online shops,
• own brands,
• repackaging,
• Changes within the supply chain.

Anyone who sources chemicals directly from outside the EU and places them on the market within the Union should therefore review their specific role and responsibility particularly carefully.

Which planned labelling rules were postponed?

This is currently one of the biggest sources of error with CLP products.

With the 2024 reform, more detailed requirements were planned, among other things, for:

• font sizes,
• formatting of labels,
• spacing,
• updating or relabelling,
• advertising,
• Distance-selling offers.

Anyone who reads older information may conclude that these requirements already apply in full in 2026.

That is no longer up to date.

Regulation (EU) 2025/2439 postponed several dates of application.

The new mandatory rules on, among other things:

• font size and label format,
• advertising,
• distance-selling offers,
• Deadlines for updating labelling

are now, in principle, to apply from:

1 January 2028

apply.

But that does not mean:

“Until 2028, you don’t have to do anything about labels.”

The already applicable CLP labelling obligations will of course remain in force.

Certain new additional requirements of the reform were postponed.

What does the CLP reform mean for online shops?

This point is particularly interesting for online chemicals trading.

The reform of the CLP Regulation contains new requirements for distance-selling offers.

The goal is for buyers to be able to see relevant hazard information already in an online offer — not only when the bottle is delivered.

However, these new specific rules were postponed as part of the so-called “stop-the-clock” approach.

The current date of application is:

1 January 2028.

For an online chemical shop, it would nevertheless be wrong to ignore the topic completely until the end of 2027.

Product data should already be well structured today.

These include, in particular:

• unambiguous product name,
• concentration,
• purity,
• CAS number,
• EC number,
• current CLP classification,
• relevant H and P statements,
• Safety data sheet.

At Biolaboratorium.com, you can already find this information directly on the product pages for many laboratory chemicals. For example, for hydroxylamine hydrochloride, the assigned CLP hazard statements and precautionary statements are listed separately.

This benefits not only regulatory processes.

Even a buyer can check considerably faster:

Is this product suitable for my planned process, and what protective measures do we need to consider?

Does the safety data sheet also need to be updated?

The label and the safety data sheet must be consistent with each other.

If a relevant classification changes due to new CLP criteria, updating the safety data sheet may also become necessary.

ECHA points out that when a mixture is reclassified, the safety data sheet must reflect the new CLP classification and labelling.

Therefore, with a new SDS version, you should not only check:

“Has the version number changed?”

Rather:

“What has changed in terms of content?”

Particularly relevant are, among other things:

Section 2

Possible hazards and labelling.

Section 3

Composition/information on ingredients.

Section 7

Handling and storage.

Section 8

Exposure controls and monitoring / personal protective equipment.

Section 11

Toxicological information.

Section 12

Ecological information.

Section 15

Regulatory information.

A changed classification can also affect operational documents.

For example:

• Hazardous substance register,
• Operating instructions,
• Risk assessment,
• Storage concept,
• Approval procedure.

What happens to existing inventory?

Transition periods exist exactly for this case.

This prevents every existing bottle from having to be immediately relabelled or withdrawn from circulation exactly on the day a new rule takes effect.

But:

A transition period does not mean unlimited protection for existing stock.

For the new hazard classes for substances, a particularly important transition period ends on:

1 November 2026.

For such older substance stocks, it should therefore be clarified in good time:

• Does the new hazard class apply to the substance?
• Which batch is available?
• When was it placed on the market?
• What labelling does it have?
• Is there an updated classification?
• Is there a new safety data sheet?
• Does the stock need to be relabelled or handled differently?

Not every old label is automatically wrong.

A bottle with an older label can fall entirely under a valid transitional provision.

Conversely, a relatively new bottle can already have outdated labelling if the classification or product data have changed in the meantime.

The age of the packaging alone is therefore not sufficient as a decision criterion.

What should companies specifically check in autumn 2026?

Instead of reassessing all chemicals at the same time, a systematic process helps.

1. Distinguish between substances and mixtures

This determines the different transition periods.

2. Obtain current safety data sheets

Especially for substances whose SDS is already several years old.

3. Compare classifications

Has Section 2 changed?

Have new hazard classes been added?

4. Prioritise products with old stock

The 1 November 2026 deadline is making older substance stocks especially relevant right now.

5. Compare labels with the current SDS

H phrases, P phrases, signal word, and product identifier should match.

6. Check supplier data

Particularly for imported products and products outside traditional EU supply chains.

7. Update internal documentation

If the hazard classification has changed, it should be checked which company documents are affected by it.

8. Inform purchasing

Otherwise, an old product variant may be reordered even though an updated label is already available.

9. Check online data

A chemical product should not be advertised in the online shop with an old hazard classification while the delivered product already bears a new label.

10. Document transition periods

For older stock, it should be possible to trace why a particular label may still be used.

What should buyers of laboratory chemicals pay attention to?

CLP is not just a topic for the legal or safety department.

Purchasing also plays an important role.

Because two offers involving the same chemical substance can differ in:

• purity,
• concentration,
• container type,
• specification,
• classification,
• available documentation.

Before ordering, therefore, it is not only the product name that should be compared.

Useful points to check are:

CAS number

Identifies the substance unambiguously.

EC number

Makes identification easier within European chemicals legislation.

Concentration

Particularly relevant for solutions and mixtures.

Purity grade

Can be critical for later use.

CLP labelling

Shows current hazard communication.

Safety data sheet

Provides significantly more detailed information on handling, storage, protective measures, and properties.

CAS and EC numbers in particular help distinguish products with similar names.

Anyone who wants to delve deeper into this topic can also read the article “CAS and EC Numbers: The Digital Fingerprint of Your Laboratory Chemicals” on the Biolaboratorium blog.

Product name alone is not enough

A practical example:

You are searching for a chemical by a familiar common name.

There is an older bottle in the warehouse.

In the online shop, you will find a product with the same name.

This does not automatically mean that:

• concentration is identical,
• hydrate form is identical,
• purity grade is identical,
• classification is identical,
• use is identical.

Therefore, the complete product specification should always be checked for laboratory chemicals.

CLP is an important part of this – but not the only one.

Does CLP automatically change the risk assessment?

Not automatically every single one.

But a changed classification is a clear reason to check whether the existing risk assessment is still suitable.

If a substance, for example, gains an additional hazard class, questions such as the following can arise:

• Are existing protective measures sufficient?
• Is the storage appropriate?
• Does an operating instruction need to be updated?
• Do employees need to be informed?
• Should substitution be considered?

The label on the bottle is thus only the visible part.

Behind it is the entire operational hazardous substance management.

Does a new CLP class automatically mean a new hazard symbol?

No.

Particularly with the European hazard classes introduced in 2023, this is a common misconception.

Since they are currently not fully represented in the UN GHS system, no corresponding new pictograms were introduced.

Therefore, a classification can change even though no completely new symbol form appears on the label.

When comparing old and new product information, therefore, not only the number of pictograms should be counted.

It is better to compare:

• complete classification,
• H statements,
• supplementary hazard information,
• current safety data sheet.

Typical mistakes around CLP 2026

Error 1: Tying all changes to one date

“New CLP rules apply from 2026.”

Too imprecise.

There are several effective dates and different transition rules.

Error 2: Treating substances and mixtures the same

Different deadlines apply for the new hazard classes.

Error 3: Overlooking 1 November 2026

This date is especially critical for substances already placed on the market before 1 May 2025.

Error 4: Adopting old articles on label formats

Some of the new requirements have since been postponed to 1 January 2028.

Error 5: Equating “no new pictogram” with “no new hazard class”.

The new EU hazard classes currently do not have their own new GHS pictograms.

Error 6: Only updating the label

A new classification can also affect the safety data sheet and internal documents.

Error 7: Only updating the safety data sheet

If the product has to be relabeled accordingly, a new PDF file in the system is not enough.

Error 8: Ignoring stock levels

Transition periods are expiring.

Old stock should therefore be checked in a targeted manner.

Error 9: Forgetting online product information

A digital product offering should not conflict with the chemical actually delivered.

Error 10: Checking only by trade name

For reliable product assignment, CAS and EC numbers as well as concentration and specification should also be considered.

Mistake 11: Automatically applying every change to all products

Not every chemical falls into a new hazard class.

The classification must be checked on a product-specific basis.

Mistake 12: Confusing a transition period with willful ignorance

Once a binding deadline is reached, the corresponding rule must be applied.

CLP Checklist for Laboratory and Operations

If you check your chemical inventories in fall 2026, you can proceed systematically.

Identify product

• Check trade name
• Check chemical name
• Check CAS number
• Check EC number
• Check concentration
• Distinguish between substance and mixture

Check documentation

• Current SDS version available?
• Issue date checked?
• Section 2 checked?
• New hazard class present?
• Labeling in the SDS compared with the bottle?

Check label

• Product identifier correct?
• Supplier fully stated?
• H-statements up to date?
• P-statements up to date?
• Signal word correct?
• Pictograms appropriate?
• Label legible?
• Additional information taken into account?

Check transition period

• When was the product placed on the market?
• Which rule applies to it?
• Does a transition period apply?
• When does it end?
• Is the decision documented?

Check inventory

• Identify older batches
• First check products with high turnover rates
• Evaluate very old individual containers separately
• Obtain updated labels or SDSs

Check internal processes

• Hazardous substance register up to date?
• Work instructions up to date?
• Risk assessment still appropriate?
• Purchasing informed?
• Employees informed?
• Online product data consistent?

Check online shop

• Chemical identification unambiguous?
• Current hazard information available?
• Product data consistent with current SDS?
• Future requirements for distance selling already taken into account in the data model?

2026 is therefore not a year in which “suddenly all chemicals will get new labels”.

The reality is more nuanced.

New hazard classes coincide with staggered transition periods, while further parts of the CLP reform are gradually becoming binding at the same time.

For companies, therefore, one thing above all is crucial:

Do not replace the entire inventory as a blanket measure; instead, check on a product-specific basis which rule actually applies.

In fall 2026, November 1, 2026 deserves special attention. For certain substances that were already in the EU supply chain before May 1, 2025, the transition period for the new hazard classes will then end.

At the same time, companies should not prematurely start label projects based on old schedules. Certain new requirements regarding formatting, advertising, and distance selling have since been postponed to January 1, 2028.

Anyone who purchases laboratory chemicals should therefore regularly review current product information, labeling, and safety data together.