Amendment to the CLP Regulation – Publication of the 23rd ATP

 

Commission Regulation (EU) 2025/1222, also known as the 23rd ATP to CLP (Adaptation to Technical Progress), was published in the Official Journal of the EU on 20 June 2025 and entered into force on 11 July 2025. It is another technical update, published periodically, to the CLP Regulation (EC No 1272/2008), aimed at aligning the classification of chemicals with the current state of scientific knowledge.

What changes does the 23rd ATP to CLP introduce?

 

The amendment covers 32 substances, including:

➤ 22 new entries to Annex VI of the CLP Regulation

Among the substances that have received harmonised classification for the first time are:

• Ozone (CAS 10028-15-6)

• Nitrogen dioxide (CAS 10024-97-2)

• Barium chromate (CAS 10294-40-3)

 

➤ 10 substances with updated classification

Classification changes may affect labelling and documentation obligations, for example:

• Vinylidene chloride (CAS 75-35-4)

• Captan (ISO) (CAS 133-06-2)

• 3-iodo-2-propynyl butylcarbamate (CAS 55406-53-6)

 

📄 The full list of substances and their new classifications is available in the regulation:👉 Legal text (PDF)

Timelines for applying the new provisions

 

• From 11 July 2025 – it is possible to voluntarily apply the new classifications (labels, packaging, documentation).

• From 1 February 2027 – mandatory implementation of the new classifications for all substances and mixtures placed on the market.

 

ATP – what is the basis for the update?

 

The CLP update via the 23rd ATP is the result of work by the Committee for Risk Assessment (RAC) at ECHA, which in 2023–2024 recommended changes based on available toxicological, ecotoxicological, and physicochemical data for substances.

Main goals of the amendment:

• Introducing harmonised classification for substances not previously classified

• Updating existing classifications in line with the latest scientific evidence

• Improving occupational safety and environmental protection

 

SDS and label updates – what must companies do?

 

If your company manufactures, imports, or uses substances covered by the new regulation, you should:

• Review the list of affected substances – available in the 23rd ATP
• Update Safety Data Sheets (SDS) – according to the new classification
• Update PCN/UFI notifications – if the classification change affects hazard identification
• Prepare new labels – for affected substances by 1 February 2027

 

🔍 Note: Changes in substance classification may also affect the labelling of mixtures containing those substances – entities using these substances in their products should carefully assess how the changes impact final product classification.

Summary: Prepare for the changes

 

The 23rd ATP to CLP is an important step towards harmonising chemical classification in the EU. It affects labelling and packaging but most importantly requires updates to safety documentation, including Safety Data Sheets.

🟢 Don't wait until the last minute – review your product portfolio now to ensure compliance before the mandatory implementation date: 1 February 2027

Want to ensure your Safety Data Sheets comply with the latest CLP requirements?

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