EU CLP Update: Aligning with Recent UN GHS Revisions

The European Commission (EC) has proposed an update to the European Union’s (EU) Classification, Labelling and Packaging (CLP) Regulation to better align with recent revisions to the United Nations’ (UN) Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

The UN GHS is reviewed biannually by the UN’s Economic and Social Council’s Sub-Committee of Experts on the GHS to consider new scientific information and learnings from implementation exercises. Subsequent outcomes can include revisions to elements of GHS, such as classification criteria, hazard statements, precautionary statements, or labelling elements. Adoption of the GHS is voluntary, leading to differing implementation of these revisions across jurisdictions. In the EU, there is an existing commitment to implement the GHS, and the CLP Regulation is periodically amended to ensure alignment.

The notification, published on 17 August 2026, announces integration of GHS revisions eight to 11 into the CLP Regulation, with the following changes:

• New classification criteria or procedures, hazard communication elements, decision logics, and guidance for chemicals under pressure, as well as amendments to better address their explosion hazard when they are not in their transport configuration;

• Revised and further rationalised precautionary statements to inter alia improve users’ comprehension while also taking into account usability for labelling practitioners;

• The use of non-animal testing methods for the classification of health hazards relating to certain hazard classes;

• The introduction of new provisions for the use of in vitro/ex vivo data and non-test methods of assessing skin corrosion and skin irritation;

• The alignment of the classification strategy, guidance, and tools on metals and metal compounds with the provisions for long-term aquatic classification toxicity;

• Amendment of the classification criteria and provisions for skin-sensitising mixtures, thus concluding the work that was initiated in the tenth revised edition with the revision of the classification criteria for substances with skin-sensitising properties; and

• Amendments to the classification criteria for substances and mixtures that are hazardous to the atmospheric system, as well as further rationalisation and streamlining of precautionary statements.

The EC has proposed adoption of these amendments in the fourth quarter of 2026. Following publication in the Official Journal of the EU, the amendments are expected to enter into force twenty days after publication. The amendments regarding classification criteria and provisions for skin-sensitising mixtures and substances and mixtures that are hazardous to the atmospheric system, detailed within the eleventh revision of the GHS, would typically be implemented at a later date, but have been brought forward to address the identified shortcomings.

Stakeholders can provide comments regarding the notification up until the final date of 16 October 2026, through contact with the relevant team at grow-eu-tbt@ec.europa.eu.

Announcing integration of UN GHS Revisions eight through 11 into the CLP Regulation may present challenges for businesses in managing classification updates across different versions of the UN GHS. Companies should consider carefully assessing the applicable classification criteria to ensure consistency when transitioning between and among the different GHS revisions incorporated into the CLP framework.