On June 20, 2025, a new amendment to Regulation (EC) No. 1272/2008 (CLP) on the classification and labelling of substances and mixtures was published. Delegated Regulation (EU) 2025/1222, known as the 23rd Adaptation to Technical Progress (ATP 23), introduces significant changes to the harmonised classification and labelling of hazardous substances. This revision has direct implications for industrial, professional and consumer products. It requires manufacturers to adapt many of their products to comply with the new classifications.
What does the ATP 23 update mean?
ATP 23 reflects the latest assessments carried out by the Risk Assessment Committee (RAC) of ECHA during 2023.
This update revises Annex VI, Table 3, Part 3 of the CLP Regulation, which contains the list of harmonised classifications and labelling elements, by adding new entries and updating some existing ones.
In practical terms, this means that new risks are officially recognised for certain substances, and the hazards of others are re-harmonised. This ensures that EU regulations remain aligned with current and emerging risks.
Key Changes in Delegated Regulation (EU) 2025/1222 (ATP 23)
The ATP 23 includes the following updates to the harmonised list of hazardous substances:
22 New Harmonised Classifications
New entries have been added for substances recently evaluated and now assigned a classification based on their hazardous properties.
Examples include:
Ozone: now classified as an oxidising gas, carcinogen category 2, and mutagen category 2.
Nitrous oxide: reclassified as toxic to reproduction, category 1B.
Organic nanoparticles, plant extracts and organometallic compounds, among others.
New entries added:
607-776-00-5, 612-300-00-4, 026-005-00-8, 604-103-00-7, 008-004-00-4, 007-031-00-9, 056-006-00-9, 650-060-00-2, 650-059-00-7, 607-777-00-0, 608-070-00-X, 607-779-00-1, 613-352-00-0, 603-248-00-3, 607-778-00-6, 015-209-00-2, 602-111-00-5, 602-112-00-0, 613-353-00-6, 603-249-00-9, 607-780-00-7, and 612-301-00-X.
Update to 10 Existing Entries
Some substances already subject to harmonised classification have had their entries updated. This includes the addition of new hazard categories or updates based on recent scientific data.
Examples include:
α-Methylstyrene (2-phenylpropene): now also classified as a carcinogen, category 2.
Isophorone diisocyanate: in addition to being a respiratory sensitiser, now classified as acutely toxic by inhalation, category 1.
Updated entries:
015-012-00-1, 601-027-00-6, 602-025-00-8, 607-231-00-1, 613-044-00-6, 613-045-00-1, 615-008-00-5, 616-145-00-3, 616-211-00-1, and 616-212-00-7.
No Deletions of Harmonised Classifications
Unlike the previous ATP, the 23rd ATP does not remove any entries from the harmonised classification and labelling table.
When Does Delegated Regulation (EU) 2025/1222 Apply?
The new and revised classifications will not be mandatory immediately. A transitional period has been set to allow suppliers to update the labelling and packaging of their substances and mixtures, and sell through existing stock without breaching the regulation.
This allows industry time to take appropriate steps and continue complying with legal obligations stemming from reclassifications.
Regulation 2025/1222 entered into force on July 10, 2025, 20 days after its official publication.
Its provisions will become mandatory as of February 1, 2027.
Until then, implementation is voluntary: suppliers may begin classifying, labelling and packaging in accordance with the new requirements from July 10.
However, from February 2027 onwards, all substances and mixtures on the EU market must comply with these new classifications.
How Is eQgest adapting to this CLP regulation update?
At eQgest, we stay ahead of regulatory changes to ensure continuous legal compliance for our clients’ labels and safety data sheets.
We will incorporate all updates from ATP 23 in upcoming software releases—scheduled before the mandatory application date in February 2027. This ensures that companies using eQgest will have the updated harmonised classifications available in time, enabling them to generate their labels and SDS in accordance with the new regulation, and fully comply with the current CLP Regulation.
You can consult Delegated Regulation (EU) 2025/1222 of the Commission, dated 2 April 2025, which amends Regulation (EC) No. 1272/2008 with regard to the harmonised classification and labelling of certain substances. This official document details all affected substances and their new classifications and serves as the legal reference for correctly implementing these changes.
Does your company need to adapt to ATP 23?
At eQgest, we help you stay compliant with the latest regulatory changes by automating the generation of labels and safety data sheets (SDS) in line with the CLP Regulation. Contact us to learn how our software can help you stay up to date.
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