Insights - The 2024 CLP Revision Beyond the Hazard Classes: Digital Labels, Format Rules, and Online Sales

When the CLP revision is discussed, one topic absorbs all the attention: the new hazard classes for endocrine disruptors and persistent substances. Fair enough — they change classifications, and classifications change everything downstream.

But the revised CLP Regulation ((EU) 2024/2865, in force since December 2024) rewrote a lot more than the hazard-class list. The rest — digital labelling, binding format rules, online sales obligations, refill station requirements — targets the mechanics of how labels work and how chemicals are sold. The bulk of these provisions apply from 1 July 2026. Most compliance teams are still running the hazard-class impact assessment. These are arriving in parallel.

The thread through all of them is the same: each new requirement adds a new rendering of the same underlying classification record — a new surface that must stay current alongside the physical label, the SDS, and the C&L notification. Every additional rendering is a new place where classification data can drift, and where an audit or a failed submission will find it.

Here is what the revision actually changed, and what the operational consequences are.

Digital labels arrive — with limits

For the first time, CLP formally allows a digital label: part of the label information provided through a data carrier such as a QR code, linking to a digital page that must be free to access, available to all users, and not track them.

The limits matter more than the headline. The core hazard communication — pictograms, signal word, hazard and precautionary statements — stays on the physical label. Digital-only provision is reserved for selected supplementary information, and the digital version must stay available for years and remain in sync with the physical one. Which quietly creates a new consistency surface: one more rendering of the classification record that can drift, alongside the label, SDS, and C&L notification.

For the first time, CLP prescribes label formatting

Until now, CLP told you what goes on a label but said little about how it must look — which is how the multi-language labels we described in our label-pitfalls post ended up legible in theory only. The revision changes that: it introduces binding formatting requirements, including minimum font sizes tied to package size and minimum line spacing, and it widens the conditions for fold-out labels as the sanctioned escape route for multilingual packs.

The practical consequence is unglamorous: label artwork that today passes on content may fail tomorrow on typography. If your labels were already crowded, the font floor turns a design annoyance into a compliance finding — and makes fold-out formats or digital supplements the realistic options for small packaging.

Selling chemicals online stops being a grey zone

The revision tightens distance selling from two directions:

The offer itself must communicate hazards. Anyone selling a hazardous chemical online must make the label information visible before purchase — the buyer clicking “order” is the moment hazard communication has to have happened, not the parcel arriving.

Someone in the EU must be responsible. Chemicals placed on the EU market, including via online sales from outside the EU, need a supplier established in the Union who answers for CLP compliance. The direct-from-overseas webshop model loses its regulatory blind spot — and the accidental-importer trap we described for buyers gets a mirror-image rule on the seller side.

Refill stations get rules

The sustainability-driven model where customers bring their own containers to refill detergents, cleaning products, and similar products is now explicitly regulated under CLP for the first time. The revision defines which products qualify — not the most acutely hazardous categories — what information must be displayed at the refill station itself, and what the customer’s own container must carry when they leave.

That last point is the consequence most upstream suppliers haven’t mapped. The information at the refill station — pictograms, signal word, hazard statements — is a live rendering of the product’s classification, displayed in retail, sitting on a shelf or counter until someone in the chain acts on a change. If a new ATP moves a mixture into a different hazard category, the refill station display is immediately out of sync. The customer’s container carries the old classification. The obligation to ensure accuracy traces back to the supplier who provided the product — and the classification record behind it.

If your downstream customers are experimenting with refill retail, their compliance posture on this provision depends directly on how current your classification data is, and how quickly a change in it reaches them.

The dates to plan around

The revision entered into force in December 2024, but its obligations phase in. The bulk of the new labelling and sales provisions apply from 1 July 2026, with transition windows for products already on the market running years longer — and, as always, per-provision details worth verifying against the regulation itself before you re-run artwork. The safe planning assumption: label projects started in 2026 should be designed against the new format rules from the start, so you don’t produce artwork with a built-in expiry date.

How 4chems helps

The thread through all of this is the one we keep pulling: every one of these changes is a new rendering requirement on the same underlying classification data. Concretely, what we do:

• Keep the source record current. On a managed IUCLID environment, the classification and labelling data behind your labels tracks the ECHA release cycle — including the revision’s new fields and the 2026 hazard classes — without an upgrade project on your side.
• One record, N renderings. With classification maintained once in IUCLID, the physical label, the digital label page, the SDS, and the C&L notification are derived views — the drift risk the revision multiplies is contained at the source.
• Scope the impact before the deadline. We help teams walk their portfolio against the July 2026 provisions the same way we do for the hazard classes: find the affected products before an inspector or a blocked shipment does.

Redesigning labels in 2026 anyway? Talk to an expert — design them against the revision once, instead of twice.

The revision cycle is not pausing

On 2 September 2026, the European Commission published a draft delegated regulation to align CLP with GHS Revisions 8, 9, and 10 — and selected provisions from Revision 11. The comment period closes 16 October. Adoption is expected in Q4 2026; the new requirements become mandatory approximately 24 months after entry into force.

The changes in scope: a new classification category for chemicals under pressure, revised P-statements, non-animal testing methods, updated aquatic toxicity criteria for metals.

Teams now adjusting to the July 2026 provisions of the 2024 revision are entering the next cycle before the current one has fully landed. The organisations managing classification as a structured, updatable record absorb these cycles as version updates. Those maintaining it in document-based workflows face the same migration problem on a shorter timeline, each time.