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New hazardous substance labeling: CLP deadlines for manufacturers of substances and mixtures

Transition periods for the new CLP classifications

The change has been official since 31.03.2023¹There are new classifications for hazardous substances that cover the topics of endocrine disruption in humans and the environment and the bioaccumulation and mobility of a substance in the environment.

In this blog post, we will briefly go into the details of the classifications again as an overview and then look at which transition periods have already passed and which are coming up soon.

What new classifications will be added?

To be reclassified:

What are the deadlines and what do they apply to?

The deadlines are specified in the CLP Regulation, Annex I in the respective subsections (e.g. for ED HH in 3.11.2.4 ² and 3.11.3.4 ³), in which the new classifications are defined.

A basic distinction is made between substances and mixtures and whether they are being placed on the market for the first time or are already on the market.

Classification and labeling according to the new classifications is mandatory from the date indicated.

Deadlines for substances

Newly placed on the market: Deadline May 01, 2025, i.e. already mandatory
Already on the market: Deadline November 01, 2026, i.e. only a few months left

Time limits for mixtures

Newly placed on the market: Deadline May 01, 2026, i.e. only a few weeks left
Already on the market: deadline May 1, 2028, i.e. more than two years to go

What do I have to do to remain legally compliant?

Obligations for manufacturers of substances

As a manufacturer of substances, your product portfolio should already be updated accordingly, but when updating safety data sheets, also bear in mind your obligations within the supply chain: you must provide customers with an up-to-date safety data sheet free of charge for the last 12 months. (REACH Regulation Art. 31, para. 9)⁴

Obligations for manufacturers of mixtures

As a manufacturer of mixtures, you still have time for existing products, but the deadline for new products is just a few weeks away. In addition to the deadline, please refer to Article 31(9) of the REACH Regulation, which stipulates that safety data sheets must be updated if the following changes occur: New hazard classifications, changes in composition, new limit values, refusal/granting of an authorization or new legislation.

How can GeSi Software GmbH support you?

SDBcheck® – Automatic check of new classifications

On the one hand, the new classifications are already read out in our free online tool SDBcheck® and also taken into account in the plausibility check.

GeSi³ – Integration of the new CLP classifications

The data can then be transferred directly to GeSi³, where the new classifications are also integrated.

ECHA Connector – Direct data retrieval for substances

Alternatively, you can use the ECHA connector for substances, where the new classifications are also adopted.

Automatic classification calculation for recipes

Of course, the new classifications will also be taken into account when calculating the classification of formulations and will then appear in your updated safety data sheets.