Classification, Labelling and Packaging

These changes have consequences for authorisation holders of plant protection products and biocidal products. Below we have listed the changes and the actions that authorisation holders need to take.

1. What has changed?

New hazard classes

Several new hazard classes have been introduced in the CLP Regulation: 

• Endocrine disruptor (ED) 
• Persistent, Bioaccumulative and Toxic (PBT)
• Persistent, Mobile and Toxic (PMT)
• Very Persistent and very Bioaccumulative (vPvB)
• Very Persistent and very Mobile (vPvM)

The ECHA website has more information on these new hazard classes.

Revised criteria 

The guidance document on using CLP criteria has been revised to support the new hazard classes. It has been split into five components. See ECHA website: Guidance documents.

Other changes

The revision of the CLP Regulation includes additional changes:

• Improved communication of hazards. New labelling requirements provide clearer information on chemical substances and mixtures.
• Digital and circular economy. The revised Regulation responds to developments in digital technologies and sustainability with the aim of improving the safety and sustainability of chemicals.

On the ECHA website a full overview is available in the official publication of the revised CLP Regulation.

2. Timelines and deadlines

Important dates

• 1 May 2025 New active substances that are placed on the market from this date must comply with the new hazard classes. For substances that were already on the market before this date, a transition period is in force until 1 November 2026.
• 1 May 2026 New products that are placed on the market from this date must be classified according to the new hazard classes. For products already on the market before this date, the transition period is in force until 1 May 2028.

For authorisation holders:

Authorisation holders should submit applications for amended authorisations to the Ctgb as soon as possible. This ensures that decision-making can be completed within set deadlines. More details on implementation dates and transition periods can be found on the ECHA website new hazard classes.

3. What actions are required?

For active substances (biocidal products and plant protection products)

Use the combined template for substance assessment and the CLH (Harmonised Classification and Labelling) report, which includes the new hazard classes.

• On the ECHA website the biocidal products template is available .  See "Combined CAR and CLH template (including the new CLH hazard classes)" 
• Plant protection products: the template is available on the EU Commission website Guidelines on Active Substances and Plant Protection Products. See Templates To Be Used For Assessment Reports and Proposals for Classification under "Procedural Guidance". 

If the substance dossier has not yet been submitted: 

Use the correct template when submitting your dossier.

If the substance dossier has already been submitted to the Ctgb: 

• Notify the Ctgb if the proposed substance classification needs to be changed due to the new requirements.
• If the Netherlands is the evaluating Member State, contact the Ctgb project leader about the classification and any additional work that may be required due to the new hazard classes.

For products (biocidal products and plant protection products)

• Check whether a change in the classification will affect your product. You might have to change the label, or the authorisation itself might be affected.
• For authorised products, submit an application for amendment via the Ctgb or R4BP (the ECHA registry of biocidal products).
• For pending applications, inform the Ctgb project leader if the proposed classification for the product needs to be changed due to the new requirements.

Go to our comprehensive FAQ page for more information about the changes to the CLP regulation. This page will be updated regularly with new information and additional questions as they become relevant.