What changed
Under Commission Delegated Regulation (EU) 2023/707, the EU introduced four new hazard classes into CLP:
- Endocrine disruption for human health
- Endocrine disruption for the environment
- PBT / vPvB — persistent, bioaccumulative, toxic / very persistent, very bioaccumulative
- PMT / vPvM — persistent, mobile, toxic / very persistent, very mobile
The application dates are staggered by substance/mixture status:
| Item | Application date |
|---|
| New substances placed on the market | 1 May 2025 |
| Substances already on the market | 1 November 2026 |
| New mixtures placed on the market | 1 May 2026 |
| Mixtures already on the market | 1 May 2028 |
The 1 May 2025 date for new substances has passed. The deadline most companies still have open is 1 November 2026, when substances already on the EU market before 1 May 2025 must meet the new criteria.
Why this matters
This is not only a label update. The new hazard classes can affect substance and mixture classification, SDS Section 2, label elements, PCN/UFI consistency, REACH dossier updates, customer declarations and workplace risk assessments.
A point that is easy to miss for global companies: these hazard classes are part of EU CLP, but they are not currently UN GHS hazard classes. SDS systems must manage them jurisdiction by jurisdiction rather than assuming one global classification carries over.
Who is affected
- Substance registrants with products already on the EU market before 1 May 2025
- Mixture producers approaching the 1 May 2026 / 1 May 2028 dates
- SDS and label owners managing EU CLP alongside other jurisdictions' GHS systems
Recommended actions
- Review affected substances against the endocrine-disruption, PBT/vPvB and PMT/vPvM criteria.
- Document the classification rationale for each substance so the decision is traceable.
- Update SDS Section 2 and labelling systems ahead of the deadline.
- Check downstream consistency — PCN/UFI data, REACH dossiers and customer declarations — against any reclassification.
- Prepare release controls so the compliant version ships from the effective date.
- Track the substance deadline (1 November 2026) separately from the mixture deadlines, since they are not aligned.
Reviewed by CHEMREG Regulatory Team · Last reviewed 16 Sept 2026