FAQ's on important changes to the CLP Regulation

The revised CLP Regulation has introduced four new hazard classes:

• Endocrine disrupting (ED)
• Persistent, bioaccumulative and toxic (PBT)
• Persistent, mobile and toxic (PMT)
• Very persistent and very mobile (vPvM)

In addition, the criteria for these new classes have been added to the ECHA guidance document on using the CLP criteria. The revised Regulation also includes new labelling requirements and changes that respond to the digital and circular economy.

More information can be found on the ECHA website New hazard classes.
 

These changes apply to all chemical substances and mixtures, which makes them relevant for the following stakeholders:

• Applicants for: 
  • New active substances in plant protection products and biocidal products
  • New plant protection products and biocidal products.
• Authorisation holders of plant protection products and biocidal products that are already on the market.

Applicants and authorisation holders must ensure that their products and dossiers comply with the new hazard classes and requirements.

If the classification of your substance or product has changed:

• Check whether this affects your product.
• If necessary, revise the label and/or assess the impact on the authorisation.
• For plant protection products, submit an application for administrative amendment to the Ctgb. For biocidal products, use R4BP.

The most important deadlines are:

Substances

• 1 May 2025 Active substances that are placed on the market from this date must comply with the new hazard classes. 
• For substances already on the market before this date, there is a transition period until 1 November 2026.

Products

• 1 May 2026 New products that are placed on the market from this date must comply with the new hazard classes. 
• For products that were already on the market before this date, there is a transition period until 1 May 2028.

Biocidal products

The biocidal products template is available on the ECHA website: Formats and templates. See "Combined CAR and CLH template (including the new CLH hazard classes)". 

Plant protection products

The template can be found on the EU Commission website Guidelines on Active Substances and Plant Protection Products. See under "Procedural Guidance" Templates To Be Used For Assessment Reports and Proposals for Classification. 

If the Netherlands is the evaluating Member State and the dossier has already been submitted to the Ctgb, a project leader from the Ctgb will contact you if additional work is needed due to the new hazard classes.

If I believe that the proposed classification should be changed? Please inform the Ctgb as soon as possible.
 

New labelling requirements clarify the communication about hazards. This could result in changes to the following:

• The design and content of your labels.
• The way in which you provide information to buyers.

See ECHA for more details on Revised CLP rules.

• Keep an eye on this FAQ page.
• Read the news releases on the websites of the Ctgb and ECHA.
• Subscribe to newsletters or notifications from both organisations.