AFTER 6 MONTHS OF CLARITY, THE WAITING BEGINS AGAIN! 

Ivo Erens - 21 July 2025 -

The European Commission has listened to industry feedback, and less than six months later, new proposals have been introduced to reverse the most recent changes to CLP legislation. 

As part of the Action Plan for the Chemicals Industry, the European Commission has made several proposals aimed at strengthening the chemical industry. 

What's On The Table? 

The 6th Omnibus package is part of this plan and includes the following key proposals: 

Postponement of several deadlines introduced in the latest CLP revision: 

CLP Obligation Original Date Proposed Date 
Labelling requirements & formatting 1 Jan 2027 1 Jan 2028 
Label updates 1 Jul 2026 1 Jan 2028 
Digital-only information (expanded) 1 Jul 2026 36 months (after entry into force) 
Advertising & distance selling 1 Jul 2026 1 Jan 2028 

Simplification of CLP & cosmetics regulations: 

  • Label requirements: A rollback of the label requirements introduced in the 2024 revision. In effect, a return to the pre-2024 revision requirements. 
  • Advertising requirements: While the label must still be referenced, the full hazard information no longer needs to be included- only for consumer sales. Advertising for professional users remains covered under REACH and SDS obligations. 
  • Small packaging: More exceptions for small packaging to improve label readability. 
  • Digital labels: Increased flexibility to use digital labeling. 

The Fine Print 

While the intention is to fully reverse the 2024 revision labeling requirements, the proposal also suggests clearer and improved guidance on readability. 

Additionally, it is proposed that font size requirements be aligned with food legislation. This would effectively mean a default x-height of 1.2 mm, with a 0.9 mm allowance for small labels. 

So while hard requirements may be rolled back, it is possible that the upcoming guidance will recommend font size in such a way that they become effectively mandatory by proxy. 

What's Next? 

Although the proposal may feel like a relief to many companies, it is important to stress that nothing is final yet. The legislation must still be approved by the European Parliament, and that process is far from guaranteed. 

There is significant opposition to parts of the proposal within Parliament and among several Member States. 

We’ll keep you posted!