New obligations for chemical classification in the EU. Time to update safety data sheets
As of 1 May 2025, new rules under the CLP Regulation are in force, introducing additional hazard classes for chemical substances. These changes are crucial for manufacturers and importers – for some substances, they may mean the need to update safety data sheets (SDSs) and product labels.
New hazard classes in CLP: what has changed?
Under Commission Delegated Regulation (EU) 2023/707, which amends Annex I to the CLP Regulation, new chemical hazard classes have been introduced, including:
Endocrine disrupting substances (EDs):
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Category 1: substances known or presumed to have endocrine-disrupting properties
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Category 2: substances suspected of having such properties
The new classification applies to hazards for both human health and the environment.
New hazard statements in SDSs and on labels
| Hazard class and category code | Hazard statement code | Hazard statement |
|---|---|---|
| ED HH 1 | EUH380 | May cause endocrine disruption in humans |
| ED HH 2 | EUH381 | Suspected of causing endocrine disruption in humans |
| ED ENV 1 | EUH430 | May cause endocrine disruption in the environment |
| ED ENV 2 | EUH431 | Suspected of causing endocrine disruption in the environment |
Controversies and industry response
While non-governmental organisations (NGOs) welcomed the changes, the chemical industry initially expressed concerns, especially due to the lack of interpretative guidance. It was not until 20 April 2025 – the day the legislation came into force – that ECHA (European Chemicals Agency) published relevant guidance for companies.
Industry bodies also pointed out that the EU is diverging from the Globally Harmonized System (GHS), which may hinder international harmonisation of chemical classification.
Deadlines for classification and SDS updates
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For new substances: the obligation to apply the new hazard classes applies from 1 May 2025
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For substances already on the EU market: companies must adapt the classification and safety data sheets by 1 November 2026
Separate transitional periods apply to mixtures:
- For new mixtures, the new hazard classes apply from 1 May 2026.
- For existing mixtures (placed on the market before 1 May 2026), companies have until 1 May 2028 to update classification and labelling.
What should you do now with your SDSs and labels?
If you are a manufacturer, importer or distributor of chemicals:
✅ Verify the classification of your substances
✅ Check whether your safety data sheets reflect the new hazard classes
✅ Prepare to update your labels and SDSs
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