On April 23, 2024, the European Parliament adopted a significant proposal (COM(2022)748) to amend the European Classification, Labelling and Packaging (CLP) Regulation (1272/2008). This update introduces new hazard classes and provisions for labeling and packaging of chemicals, aiming to enhance safety and improve hazard communication. The next step is for the Council to adopt the law, after which it will be published in the Official Journal of the EU and come into force 20 days later.
Key Changes in the CLP Regulation Update 2024
1. Enhanced Font Size and Line Spacing Requirements
The new CLP regulation introduces more stringent requirements for font size and line spacing on chemical labels to improve readability:
Minimum font sizes:
1.2mm for packages up to 0.5 liters
1.4mm for packages between 0.5 and 3 liters
1.8mm for packages between 3 and 50 liters
2.0mm for packages over 50 liters
Line spacing: Must be at least 120% of the font size
Text appearance:
Printed in black on a white background
Single, easily legible font without serifs
Appropriate letter spacing for easy readability
2. Introduction of Folded Labels
The amended CLP regulation provides updated guidelines on the use of folded labels, offering more flexibility for packaging with limited space:
Front page requirements:
Supplier information
Product identifiers
Hazard pictograms
Signal words
Unique formula identifier (where applicable)
Reference to full safety information inside
Inner pages:
All label elements required by Article 17(1), except hazard pictograms and supplier identification
Information grouped by language
Back page:
Repetition of front page elements, excluding language abbreviations
3. Digital Labeling Support
In a significant move towards modernization, the CLP regulation update introduces provisions for digital labeling:
Optional digital-only elements: Certain label elements, such as supplemental information referred to in Article 25(3), may be provided in digital form only
Accessibility requirements:
Free access without registration or app installation
Accessible for at least 10 years
Compatible with all major operating systems and browsers
Accessible with no more than two clicks
Data protection: Prohibited tracking or analysis of usage information beyond what's necessary for digital labeling
4. Regulations for Refill Stations
The CLP regulation update introduces new rules for supplying hazardous substances or mixtures via refill stations:
Labeling requirements: Refill stations must display labels corresponding to each hazardous substance or mixture supplied
Safety measures:
Risk mitigation to minimize exposure to humans and the environment
Prevention of uncontrolled use by children
On-site supplier availability for maintenance and emergency assistance
Prohibited substances: Certain hazardous substances are not allowed at refill stations, including those classified as:
Acutely toxic
Corrosive
Carcinogenic
Mutagenic
Toxic for reproduction
Respiratory or skin sensitizers
5. New Hazard Classes
The update introduces new hazard classes to better identify and communicate risks:
Endocrine disruptors for human health and the environment
Persistent, bioaccumulative, and toxic (PBT) substances
Very persistent and very bioaccumulative (vPvB) substances
Persistent, mobile, and toxic (PMT) substances
Very persistent and very mobile (vPvM) substances
Impact on Chemical Industry Stakeholders
The CLP Regulation Update 2024 will significantly affect various stakeholders in the chemical industry:
Manufacturers: Need to reassess and potentially reclassify their products according to the new hazard classes
Packaging designers: Must adapt designs to accommodate new labeling requirements, including folded labels and digital elements
Distributors: Required to ensure compliance with new refill station regulations and update their hazard communication strategies
IT departments: Need to develop and maintain digital labeling solutions that meet the new accessibility and data protection requirements
Safety managers: Must update training programs to include new hazard classes and labeling formats
Implementation Timeline and Transitional Provisions
The CLP regulation update includes a phased implementation to allow time for adaptation:
Entry into force: 20 days after publication in the Official Journal of the EU
General application: 18 months after entry into force for most provisions
Extended transition:
Substances and mixtures placed on the market before the 18-month mark have until 42 months after entry into force to comply
For certain label dimension and packaging provisions, compliance is required within 48 months after entry into force
Preparing for Compliance
To prepare for the CLP Regulation Update 2024, companies should:
Conduct a comprehensive review of their product portfolio against the new hazard classes
Assess current labeling practices and identify necessary changes
Develop a strategy for implementing digital labeling, if applicable
Review and update safety data sheets to reflect new classifications
Train employees on the new requirements and hazard communication methods
Consider the impact on global trade and align with other international chemical regulations
Our Services: Navigating the CLP Regulation Update 2024
At Innovative Services, we offer comprehensive services to help your business navigate the complexities of the CLP Regulation Update 2024. Our team of experienced regulatory experts is ready to assist you in achieving and maintaining compliance efficiently and cost-effectively.
1. CLP Compliance Assessment
We conduct thorough assessments of your current practices against the new CLP requirements:
Review your product portfolio for new hazard classifications
Evaluate existing labels and packaging for compliance with new standards
Identify gaps and areas requiring immediate attention
2. Customized Compliance Strategy Development
Our experts work with you to create a tailored compliance strategy:
Develop a step-by-step roadmap for implementing necessary changes
Prioritize actions based on regulatory deadlines and business impact
Create a budget and resource allocation plan
3. Label and Packaging Design Services
We help you redesign your labels and packaging to meet new requirements:
Create compliant label layouts, including folded label designs
Optimize font sizes and spacing for maximum readability
Ensure all required information is included and properly formatted
4. Digital Labeling Solutions
Our IT specialists assist in developing and implementing digital labeling systems:
Design user-friendly digital label interfaces
Ensure compliance with accessibility and data protection requirements
Integrate digital labeling with your existing IT infrastructure
5. Refill Station Compliance
For businesses operating refill stations, we offer specialized services:
Conduct risk assessments for refill station operations
Develop compliant labeling and safety protocols
Create staff training programs for safe refill station management
6. Employee Training and Education
We provide comprehensive training programs:
Conduct workshops on new hazard classes and labeling requirements
Offer e-learning modules for ongoing employee education
Provide train-the-trainer sessions for your internal training teams
7. Documentation and Reporting
Our services include assistance with all necessary documentation:
Update Safety Data Sheets (SDS) to reflect new classifications
Prepare compliance reports for internal and external stakeholders
Develop and maintain a compliance tracking system
8. Ongoing Compliance Support
We offer continuous support to ensure long-term compliance:
Provide regular regulatory updates and interpretations
Conduct periodic compliance audits
Offer hotline support for day-to-day compliance questions
9. Supply Chain Communication
We help you manage communication throughout your supply chain:
Develop strategies for informing suppliers and customers about changes
Create templates for communicating new hazard information
Assist with updating procurement and sales contracts to reflect new requirements
10. Regulatory Representation
Our experts can represent your interests in regulatory matters:
Liaise with authorities on your behalf
Prepare and submit any required notifications or registrations
Advocate for your concerns in industry forums and consultations
By partnering with Innovative Services, you can ensure a smooth transition to the new CLP requirements, minimize compliance risks, and maintain your competitive edge in the European market. Contact us today to learn how we can tailor our services to meet your specific needs in light of the CLP Regulation Update 2024.
Conclusion
The CLP Regulation Update 2024 represents a significant step forward in chemical hazard communication within the EU. By introducing new hazard classes, improving label readability, and embracing digital solutions, the update aims to enhance safety and provide more comprehensive information to users of chemical products. Companies in the chemical industry should start preparing now to ensure smooth compliance with these new requirements.
For more detailed information on the CLP Regulation Update 2024 and how it might affect your business, please consult the official EU publications or speak with a regulatory expert.
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