Confusion. Restlessness. Chaos. Will there be a CLP revision - or not?

Stunned. Baffled. Unfair. 
Those are the first words that come to mind when I read the minutes from the “Reality Check Workshop; On the possible simplification of Chemicals legislation–CLP,” organized by the European Commission. From the notes, it appears the session turned into a chorus of complaints about the recently introduced CLP revision. 

Let me paint the picture: the first proposal for the CLP revision was published back in 2022. It was followed by stakeholder consultations, and let’s be honest, the lobby worked its magic both behind closed doors and out in the open. Then came the formal discussions—the Economic & Social Committee, EU Commission, EU Parliament, and the Council of the EU—all weighing in and adjusting the proposal, round after round. And after every round, the lobby kicked in again. 

So here we are, more than two years later, and most of us have been following the developments closely (at least I assume so). Sure, there’ve been some tweaks along the way, but the final version doesn’t massively differ from the initial proposal. 

So how on earth is everyone still surprised—lobbyists, industry groups, companies? Has everyone buried their heads in the sand? Or did we completely fail in informing and sharing knowledge? 
I really have to ask: how can you be shocked now that it’s official—when you’ve had two years to see it coming? 

Major changes! 

Let me be clear: these are big changes, especially when it comes to labelling requirements. This affects everyone in the supply chain and may even require a complete overhaul of product, packaging, or labelling strategies. But being surprised about the amount of work this involves? When we’ve had two years to prepare? That really blows my mind. 

Jaw-dropping. 

I read the conclusion with my mouth open: there’s talk of postponing deadlines, and even whispers about revising the requirements (which would mean another CLP revision)! 

Let’s start with the deadlines: 
I get it. A delay makes sense and maybe even deserves support. But I also understand companies that have already taken big steps toward compliance—how is it fair to grant everyone an extension when they’ve been investing, adapting, and doing the work ahead of time? 

But changing the actual requirements? A new CLP revision?? That’s just wild. 
What about the companies that have already made changes? Those who’ve adjusted their production lines and designed new labels; what about the print industry that’s invested in multilayer label production? You can’t just pull the rug out from under them with a revision of the revision. 

Let’s be realistic. 

Sure, postponing the deadline? That’s a real possibility. We’ve seen it happen before with PCN notification deadlines. Given how major these changes are, I can imagine a lot of companies would welcome that. 

But reversing the CLP revision entirely? That would require going through the exact same process that brought us the revision in the first place. You know, the one that took two years? By the time that’s done, we’re already past the deadlines! 

And let’s be honest: the same players will be reviewing (almost) the same information. Why would they suddenly change their minds? Because industry wants it? 
I just don’t see it happening. 

False hope? 

I honestly don’t see the value of this session or its outcome. As I’ve explained, it’s simply not realistic. 

Are we really going to halt everything that’s already in motion? 
Why? And based on what grounds, exactly? 

To me, it feels like the industry is being handed false hope. 

It’s the same fickleness we see in Dutch politics. One day: heat pumps for everyone! The next: oh wait, maybe not. No more gas extraction! Oh, actually—just kidding. 

Running a business requires long-term vision. And these zigzag policy decisions? They don’t help. 
But hey, that’s a topic for another blog. 

What to do!? (update) 

These are strange times and I no longer dare to give estimates of what to do. Where we previously never dared to consider this possible, it now seems to be becoming reality. Reversing part of the CLP revision less than 6 months after publication! Also check this information about the leaked proposal: LINKEDIN POST: WTF!?

Rest assured, we’re keeping a very close eye on everything, and you’ll be the first to know when there’s any news. 

Now, time to lace up and run off this frustration with a solid workout. 

Cheers, 
Ivo