This Regulation was published on 03.12.025 in the Official Journal of the European Union (see OJ L, 2025/2439, 3 December 2025) and enters into force on 23.12.2025.
This affects the following requirements under the CLP:
- Format of labelling, such as the legibility of labels, e.g. appropriate font size in relation to the size of the label
- Deadlines for re-labelling in the event of changes to classification
- Information requirements for advertising, including online advertising
- Information requirements for distance selling offers, e.g. labelling elements comparable to those of the physical CLP label in accordance with Art. 17 CLP, and
- Labelling requirements for petrol stations.
The specific content of these aspects is still to be determined. The proposal COM (2025) 531 final or 2025/0531 (COD) provides indications as to what this redesign might be. Its implementation is still pending. Regulation (EU) 2025/2439 deals exclusively with the postponement of the transitional provisions.
Originally, according to Regulation (EU) 2024/2865, the new CLP requirements for the above-mentioned aspects would have had to be implemented with a transition period until 01.07.2026 or 01.01.2027, depending on the respective provision. Regulation (EU) 2025/2439 has now postponed the date of application of these transitional provisions to 01.01.2028. Nevertheless, companies are of course free to apply the new provisions introduced by the aforementioned regulation voluntarily before the date of their application.
The reason for this is the EU’s ‘Omnibus Initiative’, which aims to simplify laws and directives in order to reduce bureaucracy. OMNIBUS VI aims to simplify regulations for the chemical industry (see European Chemicals Industry Action Plan, 8 July 2025). Regulation (EU) 2025/2439 forms the first part of the Omnibus VI package.
The second part of the Omnibus VI package is eagerly awaited. Changes to the content of the CLP have been announced. It remains to be seen whether this will allow a comprehensive revision of the CLP to be pushed through in a streamlined procedure.
Further links:
Regulation (EU) 2025/2439 (stop the clock CLP) is available at: https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=OJ:L_202502439.
The proposal COM (2025) 531 can be viewed at: https://single-market-economy.ec.europa.eu/publications/simplification-certain-requirements-and-procedures-chemical-products_en.
Do you have any questions about this news or would you like to discuss it with the author? Please contact: Nicole Rauch and Martin Ahlhaus
