The European Commission has published a proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EC) No 1272/2008, (EC) No 1223/2009 and (EU) 2019/1009 as regards the simplification of certain requirements and procedures relating to chemical products (COM/2025/531). The full text can be found here: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52025PC0531

The proposal presents an extensive analysis of the reasons and objectives, with the most important points being the deregulation of the chemical industry, simplification of requirements, and strengthening the competitiveness of EU chemical companies.

The scope of the proposal covers several regulations, including those related to cosmetics, but in this article we want to focus on the proposed changes concerning the CLP Regulation. Let’s take a look at what simplifications we can expect compared to the update of the regulation published in November 2024. You can read about the changes introduced by that CLP update here: https://www.sds-create.pl/en/clp-update-%E2%80%93-new-obligations-for-chemical-companies – we encourage you to review that text before continuing with this article.

Simplifications in the CLP Regulation

Font Size and Line Spacing

Going through the provisions on proposed changes, most companies will certainly welcome the European Commission’s decision to abandon the requirement for a minimum font size. The published proposal repeals section 1.2.1.5 of Annex I, which had introduced provisions on minimum font sizes as well as line spacing.

Packaging Not Exceeding 10 ml

Furthermore, the scope of the exemption for packaging not exceeding 10 ml may be extended. This could include the possible reduction of some pictograms where appropriate or even complete exemption from labelling in certain cases.

Use of Fold-out Labels

The option to use fold-out labels, introduced by the CLP update, has been maintained. This will undoubtedly be useful as a technical solution for products where the label design is multilingual.

Exemptions for Small or Hard-to-label Packaging

Here, the proposed amendments have not introduced changes. The provisions of Regulation (EU) 2024/2865 will most likely remain in force.

Digital Labelling

In this case, the change is minor – it extends the scope to allow additional supplier details to be provided on a digital label, provided that the main supplier is listed on the physical label.

Summary

The potential simplifications to be introduced under the proposal will certainly be welcomed by businesses. In particular, the repeal of the rules on font size and line spacing seems very helpful from the perspective of the technical feasibility of fitting labelling elements onto packaging.

Undoubtedly, some business representatives would expect broader simplifications, especially wider use of digital labelling. Nevertheless, moving away from the requirements published in November seems to be a step in the right direction in terms of deregulating the chemical industry and strengthening companies’ competitiveness.

The changes in the proposed regulation have not yet been published, so their practical application will have to wait until the regulation text is officially adopted.