CLP ATP Deadlines 2026: EU CLP ATP 22 Compliance Guides

 

EU CLP Regulation: Key 2026 ATP Compliance Deadlines and Obligations

The EU Classification, Labelling and Packaging (CLP) Regulation is regularly updated through Adaptations to Technical Progress (ATPs). These updates introduce new or revised harmonised classifications for substances, directly impacting how products are classified, labelled, packaged, and documented within the European Union.

Several CLP ATPs have mandatory application dates in 2026, making early preparation critical for companies placing substances or mixtures on the EU market — particularly non-EU manufacturers exporting into the EU.

Key CLP ATP Deadline in 2026

22nd ATP to CLP – Application Date: 1 May 2026

The 22nd ATP updates Annex VI (Harmonised Classifications and Labelling) of the CLP Regulation. From 1 May 2026:

  • New and revised harmonised classifications must be applied.
  • Substances and mixtures placed on the EU market must reflect updated classifications.
  • Labels, packaging, and Safety Data Sheets (SDSs) must be updated accordingly.
  • Suppliers are responsible for ensuring compliance for affected substances and mixtures.

While companies may voluntarily adopt the updated classifications before this date, 1 May 2026 is the mandatory compliance deadline.

Other Ongoing CLP Developments

Draft and Upcoming ATPs

The EU has notified the WTO of a draft ATP proposing additional new and revised harmonised classifications. Adoption is expected following consultation in early 2026.

23rd ATP

The 23rd ATP has been adopted and will apply from 1 February 2027. Although not a 2026 deadline, early impact assessments are strongly recommended.

Core Requirements Under the EU CLP Regulation

Companies placing substances or mixtures on the EU market must meet the following obligations:

1. Classification

  • Classify substances and mixtures according to current CLP criteria.
  • Apply mandatory harmonised classifications listed in Annex VI.

2. Labelling

Labels must include:

  • Correct hazard pictograms
  • Signal words
  • Hazard (H) statements
  • Precautionary (P) statements

Labels must be legible, durable, and provided in the official language(s) of each relevant EU Member State.

3. Packaging

  • Packaging must prevent leakage.
  • Safety requirements under CLP must be met.

4. Safety Data Sheets (SDS)

  • SDSs must be updated to reflect revised classifications and hazard information.
  • SDSs must be supplied in the official language(s) of the Member State where the product is marketed.

5. Classification & Labelling Notification

  • Updated classifications must be notified to the European Chemicals Agency (ECHA).
  • Changes must be communicated promptly throughout the supply chain.

Who Is Impacted by the 2026 Deadline?

  • EU manufacturers and formulators
  • EU importers
  • Non-EU manufacturers exporting to the EU (via importers or Only Representatives)

For non-EU companies, ensuring compliant SDSs and accurate CLP labelling reflecting harmonised classifications by 1 May 2026 is essential to maintain EU market access.

Why Early Preparation Matters

Failure to meet the 1 May 2026 deadline may result in:

  • Shipment delays or border holds
  • Market withdrawals or enforcement actions
  • Increased regulatory risk and remediation costs

Conducting early impact assessments allows companies to align classification, labelling, packaging, and SDS updates well in advance of the deadline.

Expert Support for CLP ATP Compliance

Keeping pace with CLP ATP deadlines — particularly harmonised classification updates — can be complex. Freyr’s regulatory experts support companies with:

  • ATP impact assessments
  • CLP-compliant SDS and label updates
  • Classification & Labelling notification strategies

This ensures ongoing compliance and uninterrupted EU market access.

Need support preparing for the 2026 CLP ATP deadline? Contact Freyr for tailored regulatory assistance.


Comments

Post a Comment

Popular posts from this blog

FDA GRAS Rule 2026: Key Changes, compliance & Industry Impact

Image
  FDA’s 2026 GRAS Proposal: A New Era of Food Ingredient Transparency By 2026, the U.S. Food and Drug Administration (FDA) is expected to publish a proposed regulation that would require all Generally Recognized as Safe (GRAS) determinations to be formally notified to the agency. If implemented, this rule would mark a major shift in food safety oversight—effectively ending the long-standing practice of self-affirmed GRAS determinations and ushering in a new era defined by transparency, accountability, and regulatory visibility. Understanding GRAS and Its Regulatory Role The GRAS (Generally Recognized as Safe) framework has been a foundational element of U.S. food ingredient regulation under the Federal Food, Drug, and Cosmetic Act. It allows substances to be used in food if they are generally recognized as safe by qualified experts, based on publicly available scientific evidence. Historically, companies have had two pathways: Submit a GRAS notification to the FDA ...
Read more

freya fusion vs Other RIMS: Comparison Guide for Japan

  Introduction: The Growing Demand for Smarter RIMS in Japan Every missed deadline in Japan’s pharma regulatory process can cost millions—and sometimes the market itself.  Rapid globalization, evolving PMDA guidelines, and the rising complexity of eCTD v4.0 compliance have placed enormous strain on regulatory affairs teams. Many Japanese companies still rely on  spreadsheets, fragmented systems, or legacy RIMS  platforms retrofitted with AI add-ons. These approaches struggle with speed, accuracy, and compliance readiness—especially when working across multiple regions. What’s needed is a next-generation regulatory information management system (RIMS) that can  streamline submissions, ensure compliance, and keep global teams aligned in  near  real-time . This is where  freya fusion , an  AI-First, unified RIMS platform , sets itself apart. In this blog, we’ll compare  freya fusion  with other leading RIMS solutions and analyze why it...
Read more

PFAS in Cosmetics: Why They Are Being Banned Globally

Image
  The Global Shift Away from PFAS in Cosmetics The beauty industry is undergoing a profound global transformation. Across the United States, multiple states are moving to ban PFAS (Per- and Polyfluoroalkyl Substances)—commonly known as “forever chemicals”—from cosmetic products. At the same time, Japan has taken a significant regulatory step by banning 138 PFAS under its Chemical Substances Control Law (CSCL), effective January 10, 2025. This regulation prohibits the manufacture, import, and use of these substances in cosmetics unless specific exemptions apply. As consumer demand shifts toward cleaner and safer beauty products, regulators are tightening controls on ingredients associated with long-term environmental and health risks. But what exactly is driving PFAS out of makeup bags worldwide? What Makes PFAS Problematic? PFAS represent a vast group of more than 10,000 synthetic chemicals valued for their resistance to water, oil, and heat. These properties have made them...
Read more