On 8 July 2025, the European Commission published two legislative proposals: COM(2025) 526 and COM(2025) 531. Both proposals aim to extend the transitional periods for the upcoming changes to the CLP Regulation introduced by Regulation (EU) 2024/2865, published in November 2024.

Following the publication of Regulation (EU) 2024/2865, numerous and strong concerns were raised by representatives of the chemical industry regarding the potential impact of the new requirements on product adaptation costs and the competitiveness of goods originating from the internal market. Stakeholders expressed their support for including Regulation (EU) 2024/2865 within the scope of the widely discussed "stop the clock" mechanism, which has recently been applied to several other EU legislative acts.

This mechanism involves postponing the entry into force of certain provisions of regulations and directives to provide stakeholders with sufficient time to adapt to new requirements, ultimately reducing implementation costs for companies. The same approach is now being considered for the CLP Regulation update and the above-mentioned Commission proposals.

Regulation (EU) 2024/2865 – What does the CLP update include?

The November 2024 update to the CLP Regulation introduces a range of significant changes for industry, particularly concerning product labelling and the advertising of chemical products. The new technical requirements for labels—such as font size, font colour, and line spacing—may present challenges for certain packaging types. For chemical product suppliers, this could lead to increased labelling costs or the need to switch from standard labels to more complex solutions, such as fold-out or peel-off labels.

The new provisions on chemical product advertising have also raised industry concerns, mainly due to the lack of clear guidance on what constitutes advertising material (e.g. whether product catalogues are included), as well as the need to adapt existing materials and the technical difficulties of applying the rules across commonly used marketing channels.

Will the "stop the clock" mechanism apply to the CLP Regulation?

The Commission proposals COM(2025) 526 and COM(2025) 531 signal that the Commission acknowledges and understands the concerns raised by the chemical industry. During discussions with industry representatives, the Commission responded positively to their comments and observations.

This indicates that the Commission recognises the issue and supports the idea of helping businesses adapt—a reflection of the broader political trend in the EU that seeks to make the legislative framework more flexible and, as a result, improve the competitiveness of EU-made products both within the single market and beyond.

It is therefore likely that the proposals to bring the CLP Regulation under the "stop the clock" mechanism will be favourably received and formally adopted, giving businesses more time to comply with the new requirements.

Summary

Applying the "stop the clock" mechanism to the CLP Regulation would send a clear signal that the European Commission recognises the need for greater flexibility in the regulatory implementation process and intends to provide real support to the chemical sector in the years ahead.

A further step in this direction could be a revision of the November 2024 Regulation (EU) 2024/2865 to address industry demands for greater freedom in label formatting, the expansion of digital labelling, and possibly the relaxation of requirements related to chemical product advertising.

While the Commission's support for these proposals would facilitate business operations, it may also raise concerns about the effectiveness of health and environmental protection—the original objective behind the new rules. At this stage, it is difficult to determine the scope of any future amendments to the original regulation. For now, companies should monitor the publication of the revised regulations postponing the entry into force of new provisions and closely follow the ongoing legislative process.