European Commission Proposes Delay of New CLP Labelling Rules: Two-Year Postponement for Certain Requirements

On July 8, 2025, the European Commission submitted legislative proposal COM(2025) 531, which amends three key regulations: the CLP Regulation [(EC) No 1272/2008], the Cosmetics Regulation [(EC) No 1223/2009], and the Fertilising Products Regulation [(EU) 2019/1009]. In response to industry concerns about regulatory burden, the proposal delays certain chemical labeling, advertising, and remote sales requirements until January 1, 2028.

Background

On November 20, 2024, the EU enacted Regulation (EU) 2024/2865, introducing a digital labeling system and related requirements. During the "Reality Check" online consultation held on May 16, 2025, over 570 representatives from industries, consumer organizations, legal sectors, and national regulatory authorities voiced concerns. Stakeholders widely called for a "pause" on parts of the new rules, arguing they would be difficult and costly to implement in multilingual, multi-supply-chain environments. Following the consultation, the Commission received more than 150 position papers supporting the delay.

Key Revisions

1. Extended Implementation Timelines

• Postpone label format requirements (e.g., font size, line spacing), advertising/remote sales obligations, and fuel pump labeling provisions originally scheduled to take effect on July 1, 2026, to January 1, 2028.
  
• Delay the mandatory label format rules originally set for January 1, 2027, to the same 2028 deadline.

2. Simplified Labeling Requirements

• Relax label format rules: Eliminate overly strict requirements for minimum font size and line spacing to enhance flexibility.
  
• Allow digital labels: Expand the scope of information permitted in digital formats to reduce reliance on physical labels.
  
• Remove fixed 6-month update deadlines: Replace the mandatory 6-month label update rule with a "without undue delay" standard to accommodate complex supply chains.

3. Exemptions for Small Packaging

• Clarify that packaging smaller than 10 milliliters is exempt from labeling requirements to ease compliance costs for SMEs.

4. Digital Contact Information

• Labels must include digital contact details for suppliers, defined as "any up-to-date and accessible online communication channel that allows direct engagement with the supplier without requiring registration or app downloads."

5. Fuel Pump Label Adjustments

• Simplify and delay fuel pump labeling requirements, such as removing impractical or costly elements like supplier names, quantities, and Unique Formula Identifiers (UFI).

6. Streamlined Advertising & Remote Sales Rules

• Reduce mandatory hazard information in ads, retaining only critical warnings.
• Narrow the scope of advertising/remote sales obligations, particularly for public-facing products, to avoid overlap with REACH Regulation.

Next Steps

The proposal has been submitted to the European Parliament and Council of the EU for review under the ordinary legislative procedure. If approved, the revised rules will enter into force 20 days after publication in the EU Official Journal. The Commission emphasized that this delay does not alter the regulation’s core objectives or compromise public health and environmental protections. Unmodified provisions will still take effect as originally planned in 2026 or 2027.

About CIRS

CIRS Group is a leading provider of comprehensive regulatory compliance services and solutions for chemicals, cosmetics, food and food-related products, agrochemicals, and medical devices. Its chemical team consists of experts with extensive knowledge in chemistry, toxicology, environmental science, and related fields. They are well-versed in various international regulations, including but not limited to EU REACH, CLP, GHS, TSCA, and K-REACH. Our chemical compliance services in the EU cover:

• EU REACH Registration (including OR services);
• EU REACH Evaluation Compliance Services;
• SVHC Testing;
• EU CLP Compliance;
• PoPs Compliance
• EU Poison Center Notification; and 
• EU BPR Compliance.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

Proposal