New CLP Hazard Classes: The Final Transition Deadline for Existing Substances Is Approaching

The European Unions (EU) new hazard classes are approaching the end of their transitional period for substances placed on the EU market and in the supply chain before 1 May 2025. Introduced by the EU Commission Delegated Regulation (EU) 2023/707, the new hazard classes cover the following properties:

• Endocrine disruption (ED) for human health and the environment;

• Persistent, bioaccumulative, and toxic (PBT);

• Very persistent, very bioaccumulative (vPvB);

• Persistent, mobile, and toxic (PMT); and

• Very persistent, very mobile (vPvM).

For substances already placed on the EU market and in the supply chain before 1 May 2025, the final transition deadline is 1 November 2026. From that date, the new classification requirements will apply, and substances must be classified and labelled in accordance with the new hazard classes. Substances first placed on the market from 1 May 2025 have been subject to the new rules from that date.

The approaching deadline is also relevant for Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) registration dossiers. The European Chemicals Agency (ECHA) has made the new hazard classes available in the International Uniform Chemical Information Database (IUCLID) for inclusion in REACH registration dossiers since spring 2024. ECHA states that, after the applicable transition period, it will be mandatory to indicate whether a substance is classified under any of the new hazard classes and provides specific guidance on updating REACH registrations where the self-classification of a substance changes. Importantly, ECHA states that where a substance does not meet the criteria for a new hazard class, the reasons for that conclusion should be included in the registration dosser. As outlined in ECHA’s validation and quality rules for classification and labelling notifications, ECHA’s IUCLID validation rules indicate that the current, default IUCLID entry of “hazard class not assessed” will not be accepted after the applicable transition period.

With the final 1 November 2026 transition deadline for substances approaching, registrants should be reviewing existing dossiers for alignment between the substance’s Classification, Labelling, and Packaging (CLP) regulation classification, safety data sheet (SDS), and REACH registration dossier. It is important to ensure that the dossier appropriately records the outcome and basis of the assessment under the new hazard classes.