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Understanding the EU CLP Regulation: Key Takeaways for Compliance

3 Mar 2025

As brand owners, you know how critical regulatory compliance is.

As the packaging industry continues to evolve, maintaining compliance becomes increasingly complex.

Today, we’re discussing the latest EU updates to chemical safety, specifically focusing on the EU Classification, Labelling and Packaging Regulation (CLP).

Enhanced Chemical Safety Regulations

In 2023, the CLP regulation introduced new hazard classes on a voluntary basis, allowing companies to self-classify their substances and mixtures. However, starting from 1 May 2025, compliance with these classifications will become mandatory, strengthening safety measures for chemicals in the EU.

According to ECHA, the four new hazard classes addressed by the CLP update include:

ED HH in Category 1 and Category 2 (Endocrine disruption for human health)
ED ENV in Category 1 and Category 2 (Endocrine disruption for the environment)
PBT (persistent, bioaccumulative, toxic), vPvB (very persistent, very bioaccumulative)
PMT (persistent, mobile, toxic), vPvM (very persistent, very mobile)

The purpose of these regulatory updates is to ensure chemicals are appropriately labeled and classified to provide clear communication to workers and consumers throughout the European Union.

Based on the United Nations’ Globally Harmonized System (GHS), these updates provide high levels of environmental health protection to the public.

Overall, they improve safety, transparency, and consumer awareness.

To be compliant, brands must now classify hazardous chemicals on their labeling and packaging before releasing their products to market.

Keep reading to understand how CLP impacts brands and how to prepare labeling and packaging for compliance.

Major Revisions to the EU CLP Regulation

Effective December 10, 2024, changes to the CLP regulation require specific updates to labeling and packaging.

As stated in the ECHA, the label must be attached to at least one of the packaging’s surfaces. It must also include:

The name, address and telephone number of the supplier
The nominal quantity of a substance or mixture in packages made available to the public (unless this quantity is specified elsewhere on the package)
Product identifiers
Where applicable, hazard pictograms, signal words, hazard statements, precautionary statements and supplemental information required by other legislation

Label elements of endocrine disruption for the environment (Category 1)

Signal word
Pictogram (if applicable)
Product identifiers
Hazard statements
Precautionary statements
Name, address and telephone number of the supplier
Nominal quantity of a substance or mixture

According to Theory Wen¹, Regulatory Analyst from ChemLinked, “For brand owners, if the products are classified in multiple hazard classes in addition to the new ones, the pictograms for other hazard classes should apply. If the products are classified in one of the new hazard classes only, it is not required to include any pictogram on the label.”

There are also additional changes to packaging and labeling rules that will come into effect on July 1, 2026. Per ECHA, these include:

Text and Background: The mandate for black text on a white background
Font Consistency: The use of a single, easily legible font without serifs
Spacing Requirements: Adequate letter spacing and a line spacing of at least 120% of the font size, enhancing readability

Since the point size of fonts is not an exact measurement, the European Commission will define font size based on the x-height, which corresponds to the height of a lowercase ‘x’ in a given typeface. This standard ensures consistent readability across different fonts and packaging formats.

Furthermore, there are exceptions for certain types of products and/or packaging. Wen states, “According to the Revision, for inner packaging with content less than 10 ml, label elements as required by Article 17 of CLP Regulation can be omitted under certain conditions such as for R&D purposes. However, it should contain at least the information for the pictogram, signal words, product identifier, and the name and telephone number of the supplier. The outer packaging or tie-on tag should contain all the required label elements.”

Capacity of the package	Dimensions of the label (in mm) for the information required by Article 17	Dimensions of each pictogram (in mm)	Minimum font size (x-height in mm)

Table: Minimum dimensions of labels and pictograms and minimum font size

Increased font sizes are going to require substantial growth in the size of packaging to ensure readability and comply with the CLP updates. Thus, strategic planning in label and packaging design will be essential for compliance.

The Timeline for CLP Compliance

Per ECHA, the transitional periods provided are as follows:

For Substances:

Placed on the market after May 1, 2025: Compliance with the new classification and labeling requirements is mandatory from this date.
Already on the market before May 1, 2025: A transitional period is granted until November 1, 2026, to comply with the new requirements.

For Mixtures:

Placed on the market after May 1, 2026: Compliance with the new classification and labeling requirements is mandatory from this date.
Already on the market before May 1, 2026: A transitional period is granted until May 1, 2028, to comply with the new requirements.

According to Wen, beyond the primary compliance deadlines, specific label updates must be made within shorter transition periods depending on the type of classification change.

For example, Wen notes, “If a substance or mixture is classified under a new hazard class or a more severe one, the label must be updated within six months.”

To stay compliant, Wen recommends that “brand owners assess whether their products fall under newly adopted hazard classes and ensure prompt label updates in line with the revised regulation.”

Packaging Size Implications: Navigating the Operational Impact

One of the most significant challenges the new CLP regulation poses is related to packaging size. This results from increased font size, new spacing requirements, and additional labeling elements. Brands may need to undertake substantial packaging redesigns to accommodate these changes.

This especially affects industries where packaging size impacts shipping costs, shelf space requirements, and production efficiency.

However, while the CLP updates have strict deadlines, businesses are not required to wait until the last moment to implement changes.

Businesses might consider:

Conducting early artwork assessments to determine how their packaging will be affected.
Implementing alternative label formats such as fold-out labels or QR codes for digital labeling.
Collaborating with regulatory teams to ensure compliance without compromising brand identity or consumer usability.

The revised CLP allows for more flexible use of fold-out labels, simplifying labeling and improving legibility—particularly for products that require multilingual information or have limited packaging space. These multi-page labels efficiently expand space without altering container size, making them ideal for including additional hazard information, safety instructions, and multilingual content.

Regardless of size or shape, labels can be directly adopted in the form of fold-out labels. The front page of such labels should include the following label elements:

Front Page:

Name, address and phone number
Nominal quantity of the substance or mixture
Product identifiers in all languages used in the inside pages
Hazard pictograms
Signal words in all languages used in the inside pages
Unique Formula Identifier (UFI)
Reference to the full safety information inside
Abbreviation of the language for all the languages used in the inside pages

Inner Pages:

The inner pages of the fold-out label shall contain all label elements except for pictograms and supplier information, using the language abbreviations mentioned on the front page.

Back Page:

The back page of the fold-out label shall contain all the label elements listed on the front page, except for the abbreviations of the languages that are used in the inside pages.

Additionally, the updated regulation now permits digital labels alongside physical ones. While labeling elements previously had to be physically attached to the product, brands can now use data carriers—such as QR codes—linked directly to digital labels. These must be firmly affixed or printed on the packaging, with free access provided. Digital labeling offers brands a modern solution for managing compliance and artwork, saving space while enhancing accessibility and user experience.

By adopting these strategies, brands can plan for a smooth transition and avoid costly last-minute redesigns.

Increasing regulatory demands require a scalable solution to help companies update and manage their labeling efficiently. By digitizing workflows, brands can ensure version control, audit trails, and achieve seamless collaboration across teams.

A Practical Solution for CLP Compliance

Esko WebCenter provides a streamlined approach for implementing the EU CLP updates.

More specifically:

Challenge: Frequent Label Updates & Increased Packaging Sizes

Solution: With WebCenter’s automated workflows, brands can efficiently update labels across multiple SKUs and packaging formats, ensuring that all content—including hazard statements, pictograms, and supplier details—remains accurate and compliant. This eliminates manual bottlenecks, reducing the risk of mislabeling and costly reworks.

Challenge: Managing Compliance Across Global Regulations

Solution: WebCenter ensures full traceability with audit trails, validation tools, and electronic signatures, helping companies meet ECHA, FDA, EMA, and other regulatory standards. The system automatically tracks revisions, approvals, and compliance deadlines—making audits and regulatory submissions easier and error-free.

Challenge: Ensuring Accurate and Up-to-Date Artwork & Labeling

Solution: With WebCenter’s centralized content management, businesses can efficiently manage and update labeling elements to ensure consistency across all packaging materials.

WebCenter also supports barcode verification, helping companies maintain accurate and compliant labeling for regulatory submissions and production. This ensures that all packaging artwork is audit-ready and aligned with compliance requirements without disrupting workflows.

Embracing Change for a Safer Future

The latest updates to the EU CLP Regulation are a substantial step forward in chemical safety and consumer protection.

Simply put, the time is now.

Companies must not only achieve compliance, but they must also do so efficiently, accurately, and cost effectively, with as minimal an interruption in business operations as possible.

If you’re interested in learning more about WebCenter, book a discovery call!

[1] Wen’s insights from ChemLinked are intended for informational purposes only and should not be considered legal advice.