CLP Revision (EU) 2024/2865: A New Era in Chemical Classification, Labelling and Packaging

Introduction: A Milestone in EU Chemical Legislation

If you are a manufacturer exporting cleaning products, paints, adhesives, cosmetic raw materials, biocides, or any other chemical-containing products to the European Union, the labels and packaging of your products are subject to the EU's CLP Regulation (Classification, Labelling and Packaging). This regulation was formulated by Regulation 1272/2008, which has been in force since 2008.

Regulation (EU) 2024/2865 of 23 October 2024 significantly revised this fundamental text. The Regulation was published in the Official Journal of the European Union on 20 November 2024 and entered into force on 10 December 2024. This article addresses, in an educational framework, what the revision brought, which rules changed, and why the transition timetable should be carefully followed.

Important note: This regulation is a revision of chemical labeling and packaging; it is separate from the Carbon Border Amendment (CBAM) or Product Passport (DPP) regimes. The focus is on ensuring that hazard information about chemicals is communicated to consumers and professional users in an accurate, readable, and accessible manner.

• Canonical reference: Regulation (EU) 2024/2865, CELEX 32024R2865.
• The text it amended is: CLP Regulation No. 1272/2008.
• Published: 20 November 2024 (Official Journal of the EU) — Entered into force: 10 December 2024.
• Scope: Classification, labelling and packaging of substances and mixtures offered for sale on the EU market.

What is CLP and what changes with this revision?

CLP is the EU framework that defines how chemicals should be classified according to their hazards (flammability, toxicity, environmental damage, etc.), labeled with hazard pictograms, warning words (“Danger”/”Caution”) and H/P statements, and safely packaged. It is compatible with the United Nations Global Harmonized System (GHS).

Law 2024/2865 does not replace the existing system; it updates it to the realities of the digital age and modern supply chains. The revision aims to close gaps in the online and distance selling of hazardous materials, improve label readability, and clarify the responsibilities of each actor in the supply chain.

The main innovations brought about by the revision are summarized in the following points. Most of these innovations cover the entire lifecycle of the product, from the physical label to advertising and sales channels.

• Labeling in online and distance selling: When hazardous materials are sold online, all mandatory hazard information must be displayed in the sales advertisement.
• EU-based supplier requirement: Online sales to consumers must have a responsible supplier based within the EU; this prevents non-EU sellers from circumventing the rules.
• New labeling rules: Minimum font size and formatting rules have been defined, as well as fold-out and digital label options.
• Digital labeling: Some labeling elements may be presented in digital format; however, digital labels do not replace physical labels, but rather complement them.
• Hazard information in advertisements: Advertisements for hazardous materials must include information on their hazard class.
• Refill station sales: Specific labeling requirements have been introduced for sales made to consumers via open containers/refills.
• Substance group assessment and MOCS: New rules have been added regarding the classification of substances containing multiple components (MOCS) and provisions for the assessment of substance groups.
• Supply chain actors' responsibilities: The roles and responsibilities of manufacturers, importers, distributors, and downstream users have been clarified.

New Labeling and Online Sales Rules

The most visible practical effect of the revision will be on the labeling. Minimum font size and formatting rules have now been established for label readability. For situations where all information cannot fit on small packages, a fold-out label solution has been officially defined; this ensures that hazard information is presented completely but legibly.

Digital labeling is one of the most talked-about innovations of the revision. It allows certain label elements to be provided digitally using tools such as QR codes. However, the critical point is this: the digital label does not replace the mandatory minimum content of the physical label; it complements it. Information vital for security purposes remains physically present on the product.

On the online sales front, the regulation closes a long-standing gap. When a hazardous substance or mixture is offered for sale online, the advertisement itself must display the relevant hazard information. Furthermore, the requirement for a responsible supplier based in the EU for sales to consumers directly impacts the supply chain structure for non-EU exporters.

• Minimum font size and formatting standards will be applied to labels.
• Fold-out labels have become recognized as an official solution for small packaging.
• Digital labels are voluntary and complementary; they do not replace physical labels.
• Warnings about hazards must be displayed in online sales listings.
• For distance selling to consumers, a requirement for responsible suppliers based in the EU is coming.
• Advertisements should include information about the product's hazard class.

Important Dates and Transition Schedule (Including “Stop-the-Clock”)

The transition timetable in this regulation is complex and has recently changed once again; therefore, it should be read carefully. Regulation 2024/2865 originally envisioned a two-stage implementation timetable: July 1, 2026 (approximately 18 months after entry into force) for most provisions, and January 1, 2027 (approximately 24 months later) for the remaining form/format provisions.

However, the European Commission introduced a “stop-the-clock” mechanism to allow the sector more time to comply. Regulation (EU) 2025/2439, published on 3 December 2025 and entering into force on 23 December 2025, postponed the implementation date of key provisions to 1 January 2028. This coincides with the key date of 2028-01-01 in the COOPE engine data.

The deferred provisions include relabeling periods (Article 30), mandatory label format (Article 31(3)), information in advertisements (Article 48), distance/online sales (Article 48a) and labeling of fuel filling units (Annex II, Section 5). Companies may voluntarily implement the new rules early during the transition period if they are ready.

• December 10, 2024: Law 2024/2865 entered into force (publication November 20, 2024).
• Original calendar: July 1, 2026 (most provisions) and January 1, 2027 (formatting provisions).
• 3 December 2025: (EU) 2025/2439 (“stop-the-clock”) was published and entered into force on 23 December 2025.
• 1 January 2028: New effective date (key date) for Articles 30, 31(3), 48, 48a and Annex II Section 5.
• Voluntary early implementation: Optional compliance with the new rules is possible during the transition period.
• Note: The postponement relates to labeling/sales regulations; the transition periods for classification standards should be considered separately.

What does this mean for Turkish producers and exporters?

For Turkish companies exporting chemicals, mixtures, or products containing chemicals (cleaning products, paints, adhesives, cosmetic raw materials, additives, etc.) to the EU market, this revision directly affects labeling, packaging, and sales channel design. One of the most critical changes is the EU-based responsible supplier requirement for non-EU sellers: companies, especially those selling online to consumers, may need to review their supply chain structures.

While extending the deadline to January 1, 2028, might seem like a relief, the postponement is not an exemption. Adapting label designs to new formatting and readability rules, reviewing advertising and announcement texts, and evaluating digital label infrastructure are time-consuming processes. Companies that prepare early can gain a competitive advantage by voluntarily implementing the new rules during the transition period.

This text is for informational purposes only and does not constitute an official conformity assessment or legal opinion. For the specific classification and labeling requirements of your product, it is essential to consult the full, current text of the relevant EU legislation and, where necessary, the assessment of competent experts.

• Affected products: chemicals, mixtures, and consumer/industrial products containing chemicals.
• For companies engaged in online/distance selling, the EU-based responsible supplier model is gaining prominence.
• The label format may need revision according to minimum font size and readability guidelines.
• Hazard information may need to be added to advertisements and product descriptions.
• January 1, 2028 is not the end, but the beginning of preparation; early adaptation planning is recommended.
• Product-specific assessment and up-to-date official text are required for precise liability assessment.

Frequently Asked Questions

When did CLP Revision (EU) 2024/2865 enter into force and which text does it amend?

The regulation is dated 23 October 2024, published in the Official Journal of the EU on 20 November 2024, and entered into force on 10 December 2024. It replaces Regulation 1272/2008 on the European Communities Union (CLP), which has been in force since 2008. Its canonical reference is CELEX 32024R2865.

When do the new rules become mandatory?

The original timetable was 1 July 2026 for most provisions and 1 January 2027 for formal provisions. However, the ’stop-the-clock“ regulation (EU) 2025/2439, published on 3 December 2025, postponed the key provisions (Articles 30, 31(3), 48, 48a and Annex II Section 5) to 1 January 2028. Therefore, 1 January 2028 should be taken as the current date in the implementation planning.

Are digital labels replacing physical labels?

No. Digital labeling is voluntary and supplementary. While certain label elements may be presented digitally, mandatory minimum hazard information remains on the physical label on the product.

I sell my products online to the EU. How will this affect me?

Online sales advertisements for hazardous materials must display mandatory hazard information. Furthermore, distance selling to consumers is now required to have a responsible supplier established within the EU; this could directly impact the supply chain structure of exporters from outside the EU.

Is this arrangement the same as CBAM (borderline carbon)?

No. 2024/2865 is a chemical classification, labelling and packaging revision; it is separate from the CBAM or product passport regimes. Its focus is on the accurate and legible communication of hazard information for chemicals.

This content is for informational purposes only and does not constitute legal opinion or compliance assessment. The current official legislation text (EUR-Lex) should be used for precise requirements.