Regulation (EU) 2025/2439: new deadlines for the application of changes to the CLP

1. Why Regulation (EU) 2024/2865 was amended?

2. Objectives of Regulation 2025/2439

3. Main changes to the application dates

In July 2025, the European Commission published a proposal (COM (2025) 531) to amend Regulation (EU) 2024/2865. The proposal aimed to reduce administrative burdens and costs for companies, while maintaining a high level of protection for human health and the environment.

Subsequently, on 26 November 2025, Regulation (EU) 2025/2439 of the European Parliament and of the Council was published, introducing amendments to Regulation (EU) 2024/2865. This change focused on updating the application dates and establishing transitional provisions to facilitate its implementation.

This new regulation responds to the need to harmonise the deadlines for implementing the technical, administrative and labelling measures provided for in Regulation 2024/2865, thus ensuring an orderly and effective transition in the internal market for hazardous substances and mixtures.

Why Regulation (EU) 2024/2865 was amended?

Regulation (EU) 2025/2439, which amends Regulation (EU) 2024/2865, introduces changes to Regulation (EC) No 1272/2008.

The former, published in July 2025, introduced specific rules on label formats, deadlines for relabelling, information requirements, rules for fuels at service stations, and also postponed the initial application of these rules.

However, the increase in the complexity and volume of requirements has raised concerns among companies, particularly regarding the administrative burden and associated costs.

For this reason, the European Commission has proposed simplifications and decided to postpone the entry into force of the most complex amendments in order to ensure a gradual and coherent implementation.

In addition, Regulation (EU) 2025/2439 does not introduce new substantive obligations, but rather reorganises and delays their application, which is particularly relevant for the chemical industry and for marketers of substances and mixtures within the EU.

Objectives of Regulation 2025/2439

In addition to the main objectives related to the adoption of Regulation (EU) 2024/2865—such as reducing administrative burdens and costs, extending adaptation deadlines and easing aspects that pose greater compliance difficulties—Regulation 2025/2439 also aims to:

• Ensure that changes to labelling and classification are implemented in a coordinated manner across the European Union, avoiding differences between Member States.
  

• Establish transitional periods so that substances and mixtures already placed on the market before the new dates can remain on the market for a limited time without the need for immediate relabelling.
  

• Improve consumer information and safety in the use of hazardous substances in order to strengthen health and environmental protection, despite the extension of deadlines.

Main changes to the application dates

According to the official amendment document, postponing the initial deadlines will allow economic operators to better prepare for changes in labelling and information requirements.

Below is a summary of the main changes to the application dates:

Scope | Application date – Regulation 2024/2865 | New application date – Regulation 2025/2439

• Art. 30 CLP – Relabelling deadlines
  1 July 2026 / 1 January 2027 → 1 January 2028

• Art. 31(3) CLP – Mandatory format requirements (font, spacing, etc.)
  1 January 2027 → 1 January 2028

• Art. 48 CLP – Information requirements in advertising (distance selling offers added)
  1 July 2026 → 1 January 2028

• Art. 48a CLP – Distance selling
  1 July 2026 → 1 January 2028

• Annex I (Parts 2 and 3) – Labelling format
  1 January 2027 → 1 January 2028

• Annex II (Part 5) – Labelling of fuel dispensers
  1 July 2026 → 1 January 2028

• Annex IV – Stricter labelling rules
  1 July 2026 → 1 January 2027

• Art. 1(9) CLP – Downstream users, importers and distributors: obligation to provide relevant information for an appropriate health response
  1 January 2026 → 1 January 2027

• Art. 1(24) CLP – Member States and distributors
  1 July 2026 → 1 January 2027

• Art. 1(15) CLP – Affixing of labels, fold-out or digital labels
  1 July 2026 → 1 July 2026

• Art. 1(17) CLP – Labelling templates
  1 July 2026 → 1 July 2026

• Art. 1(18) CLP – Recharging stations
  1 July 2026 → 1 July 2026

• Art. 1(22) CLP – Specific limits, M factors and ETA
  1 July 2026 → 1 July 2026

• Annex I (4) CLP – Fold-out labels (new information)
  1 July 2026 → 1 July 2026

• Annex I (11) CLP – Digital labels (new information)
  1 July 2026 → 1 July 2026

• Annex II (1) CLP – Supply – Recharging stations
  1 July 2026 → 1 July 2026

• Annex I (10) – Labelling exemptions
  1 January 2026 → 1 July 2026

• Voluntary application – (Art. 2.4, 2.5 CLP)
  30 December 2024 → 31 December 2027
  

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