2026 Chemical Compliance Calendar (CLP/SDS/PCN-UFI)

Broken down by quarter, with practical checkpoints

MSDS-Europe – Compass for Chemical Safety – 2026 Chemical Compliance Calendar (CLP / SDS / PCN-UFI)

For the European chemical industry and the economic operators participating in the chemical supply chain, 2026 will be one of the most complex periods of the past decade from a regulatory compliance perspective.

The purpose of this article is to help businesses working with chemicals and mixtures (manufacturers, importers, distributors, webshops) review the most important annual compliance tasks on a yearly timeline: Safety Data Sheets (SDS), CLP labelling, PCN notifications and UFI, supplier documentation and online sales.

Key definitions (briefly, without misunderstandings)

Substance: a single chemical element or compound (e.g., ethanol).

Mixture: a solution composed of two or more substances (e.g., cleaning agent, paint, adhesive).

CLP Regulation (Regulation (EC) No 1272/2008): the EU framework for the classification, labelling and packaging of substances and mixtures (hazard classes, pictograms, hazard statements (H statements), precautionary statements (P statements), EUH statements, etc.).

Safety Data Sheet (SDS): a standardised, structured document prepared for users, providing information on the hazards of a substance/mixture and on safe handling, storage and disposal; it follows a 16-section format.

PCN (Poison Centre Notification): a notification of the composition and toxicological information of hazardous mixtures to poison centres, in the harmonised format set out in Annex VIII to the CLP Regulation.

UFI (Unique Formula Identifier): a 16-character code used to link the PCN notification and the label (for mixtures).

New CLP hazard classes (Commission Delegated Regulation (EU) 2023/707): including endocrine disruptors (human health/environment), PBT/vPvB, PMT/vPvM – these introduce new classification and labelling considerations and, in some cases, new EUH statements.

Key 2026 dates worth scheduling in advance

1. New hazard classes – mixtures (newly placed on the market)

1 May 2026: the new hazard classes apply to mixtures placed on the market from 1 May 2026.

2. New hazard classes – substances (already on the market)

1 November 2026: the transitional period for substances already placed on the market ends; from this date, compliance with the new hazard classes is mandatory.

3. PCN – the harmonised format is now a baseline expectation

From 1 January 2025, PCN notifications for all hazardous mixtures placed on the EU market must be submitted in the harmonised format; in 2026, the focus is typically on quality, updates and change management.

4. CLP online sales/advertising – deadline postponed

It is important to note that, for the CLP “online” rules, the previously communicated application dates for 2026–2027 have been postponed to 1 January 2028 (including requirements for advertisements and distance-selling offers).

Therefore, the right approach in 2026 is data and interface preparation, not a “last-minute” switchover.

5. PFAS (per- and polyfluoroalkyl substances) – two parallel tracks in 2026

• PFAS in firefighting foams: the restriction was adopted in 2025 and becomes applicable from October 2026 (with phased transitional periods).
• Assessment of an EU-wide PFAS restriction: ECHA’s aim is to complete the scientific assessment by the end of 2026.

New hazard classes – the evolution of the CLP Regulation

The European Commission recognised that the previous classification framework did not adequately address long-term risks such as endocrine disruption or environmental mobility.

As a result, Commission Delegated Regulation (EU) 2023/707 was adopted, which introduced six new hazard classes into the EU legal framework.

The scientific criteria and mechanisms behind the new hazard categories

The introduction of the new classes is not merely an administrative change – it is also a scientific paradigm shift.

For identifying endocrine-disrupting properties, the legislator relied on the World Health Organization (WHO) definition. A substance is considered an endocrine disruptor if endocrine activity is demonstrated, an adverse effect is observed in an intact organism, its progeny or (sub)populations, and there is a biologically plausible causal relationship between the two.

The persistent, bioaccumulative and toxic (PBT) / very persistent and very bioaccumulative (vPvB) and persistent, mobile and toxic (PMT) / very persistent and very mobile (vPvM) hazard classes aim to address environmental risks.

While PBT substances pose a hazard due to their accumulation in the food chain, PMT substances, because of their mobility, can enter the water cycle and travel far from the source, reaching areas where their concentrations become difficult to control. This property is particularly critical for the protection of drinking water resources.

The table below summarises the new classes and their associated codes:

Transitional periods and key 2026 dates

For mixtures, the date of 1 May 2026 is a clear dividing line: any mixture placed on the EU market from that date must comply with the new classification rules.

For substances, the deadline of 1 November 2026 is the final date for so-called “legacy” substances already on the market. After that, no substance may remain on the market if its label and Safety Data Sheet do not include the relevant information required under the new hazard classes.

The table below illustrates the logic of the process:

The table highlights a critical strategic point: although mixtures already on the market are granted a grace period until 2028, the November 2026 switchover for raw materials (substances) will force mixture manufacturers to review their formulations by the end of 2026, because SDS updates will start arriving from suppliers in an avalanche.

CLP online sales/advertising

The revision of the CLP Regulation and the “Stop the Clock” mechanism.

Regulation (EU) 2024/2865 is the most comprehensive textual amendment to the CLP Regulation to date, focusing on digitalisation, online commerce and administrative simplification.

However, due to concerns raised by industry stakeholders, the European Parliament and the Council adopted Regulation (EU) 2025/2439, commonly referred to in the industry as the “Stop the Clock” Regulation.

Under the amendment adopted at the end of 2025, the deadlines for several key obligations were moved to 1 January 2028.

Deferrals to 2028 cover the following areas:

• Label format and readability: strict requirements on font size and line spacing.
• Online sales and advertising: the obligation to display all label elements prior to purchase in distance selling, as well as tightened requirements for hazard information in advertisements.
• Fuel stations: specific information to be shown on fuel nozzles (UFI, supplier details).

This deferral gives businesses breathing space in 2026; however, the legislator emphasises that it does not mean preparations should stop. 2026 should be the year of populating structured data (PIM systems).

PFAS and siloxanes – REACH restrictions

Annex XVII to the REACH Regulation contains restrictions for certain substances and/or mixtures.

In 2026, two areas reach a turning point that affects almost every sector: PFAS and cyclic siloxanes.

PFAS firefighting foams and the obligation to have management plans

Regulation (EU) 2025/1988 introduced entry 82 into Annex XVII to REACH, restricting the use of per- and polyfluoroalkyl substances (PFAS) in firefighting foams. Due to their extraordinary stability, PFAS are often referred to as “forever chemicals” and can cause irreversible damage once released into the environment.

Key PFAS-related deadlines in 2026:

• 23 October 2026 – Placing on the market prohibition: From this date, the placing on the market of PFAS-containing firefighting foams in portable fire extinguishers is prohibited (except for certain alcohol-resistant types that have a derogation until April 2027).
• 23 October 2026 – PFAS Management Plan: this is the most significant administrative burden for operators. Any site that uses or stores PFAS-containing foam (except portable extinguishers) must have a site-specific management plan.

The PFAS Management Plan must include:

• The exact type and quantity of foams used and stored on site.
• A description of technical measures implemented to prevent leaks.
• A protocol for the collection and disposal of waste foams and contaminated firefighting water (verified destruction technology).
• A documented strategy for switching to fluorine-free alternatives.

This documentation must be retained for at least 15 years and must be presented upon request by the competent authority (for example, disaster management or environmental authorities).

Phase-out of cyclic siloxanes (D4, D5, D6)

Regulation (EU) 2024/1328 amended entry 70 of Annex XVII to REACH, tightening restrictions on the use of cyclic siloxanes (D4, D5, D6). These substances are widely used in the cosmetics industry, dry cleaning and many industrial technologies.

Under the restriction, after 6 June 2026, octamethylcyclotetrasiloxane (D4), decamethylcyclopentasiloxane (D5) and dodecamethylcyclohexasiloxane (D6) may not be placed on the market on their own or in mixtures at concentrations above 0.1% by weight (certain exemptions are specified in the Regulation).

This deadline particularly affects cosmetic products, except for rinse-off products, which were already subject to earlier restrictions. It is also a critical date for the dry-cleaning sector, since the use of solvents containing these substances will be prohibited from that point.

Other CLP provisions entering into force in 2026

While the label format has been postponed, several technical and procedural rules become mandatory from 1 July 2026 under Regulation (EU) 2024/2865.

• MOCS substances: for the classification of substances with more than one constituent (MOCS) – such as essential oils or plant extracts – individual constituents must be taken into account similarly to mixtures where test data for the substance as a whole are not available.
• Digital labelling: the voluntary option to use a digital label (QR code) becomes available, but only under strict technical conditions: access must be free of charge, without passwords, and available for at least 10 years.
• Fold-out labels: the use of fold-out labels for multilingual or extensive information becomes standardised.

Quarterly compliance calendar for 2026

Q1 (January–March): Portfolio and documentation foundations

Objective: the company should have a clear view of which products require which documents and obligations, and where gaps exist.

Recommended steps:

• Product portfolio list: (SKU/product name, substance/mixture, user category: consumer/professional/industrial, target countries).
• SDS audit: it is not enough to have an SDS. It must be checked whether it complies with the (EU) 2020/878 format (which is already mandatory) and whether it includes the new physicochemical parameters in Section 9.
• Label check (CLP): pictograms, signal word, hazard statements (H statements), precautionary statements (P statements) and EUH statements, supplier details, and the UFI where required.
• PCN notification and UFI status review: Is there a PCN notification for every hazardous mixture? Does the UFI match on the label and in the notification? Important: the UFI must also appear in the PCN notification.
• Supplier declarations: request written confirmation from suppliers on whether the substances they supply have been assessed against the new CLP hazard classes (ED, PBT, PMT).

Downloadable checklist

Q2 (April–June): Preparing mixtures for 1 May 2026

Objective: ensure that the classification and labelling of mixtures placed on the market from 1 May 2026 are carried out with the new hazard classes taken into account. By this point, mixture manufacturers should already have reclassification data for their raw materials.

Recommended steps:

• New classification decisions: for mixtures placed on the market from 1 May 2026, assess the relevance of the new CLP classes. If a constituent is classified as an endocrine disruptor at 0.1% (w/w), the mixture must also be classified accordingly.
• Label update: although the format (font size) may be postponed until 2028, the content (new EUH statements) may not. If a substance’s classification changes after 1 November 2026, the label must also include the new EUH statement, consistent with the Safety Data Sheet.

Label versioning and approval: an internal workflow (who decides, who approves, how versions are archived).

• PCN update rules: if the composition, classification, product name, packaging or use changes, the PCN must be updated. If the classification changes (for example, a new EUH statement is added), the notification must also be updated.
• Webshop data set preparation for 2028: structured storage of the label elements to be displayed later on product pages (pictograms, H and P statements, EUH statements, UFI, etc.) (PIM/ERP fields).

Q3 (July–September): Internal audits and the start of PFAS preparation

Objective: compliance should not be a campaign, but business-as-usual operations.

Recommended steps:

• Introduce a change-management mini checklist (for every product change):
  • Is the SDS affected?
  • Is the label affected?
  • Are the PCN notification and UFI affected?
  • Is webshop data affected?
• Inventory management: before the 1 November substance deadline, it is worth clearing old-labelled substances from stock or preparing for relabelling.
• MOCS assessment: manufacturers of essential-oil- and extract-based products should check whether complex substances (MOCS) comply with the new rules effective in July.
• Supplier control: request automatic notifications of SDS updates; assign responsibility for implementing changes in internal systems.
• Internal training (short, targeted): for warehouse/customer service/marketing teams: what can and cannot be claimed about hazardous products (especially on online channels).

Q4 (October–December): 1 November 2026 (substances) + PFAS focus

Objective: ensure that the classification and labelling of affected substances is in order by the 1 November 2026 deadline; and ensure that the start of PFAS applicability in 2026 does not go unnoticed.

Recommended steps:

• Substance screening: substances in the company’s portfolio that were already on the market must comply with the new hazard classes by the deadline.
• PFAS relevance assessment:
  • are there PFAS-containing products/firefighting foams/related uses;
  • is a substitution plan required;
  • which transitional period and which obligations may apply to the specific use.

“PFAS Management Plan”: by 23 October, the firefighting foam management plan must be completed and signed, and kept on file in the site’s document archive.

• Preparation for 2027–2028 (especially webshops): despite the “stop-the-clock” deferral, structured data management and interface planning can be launched cost-effectively in 2026.

Conclusions

In the field of chemical safety, 2026 is not merely another administrative milestone, but part of a profound structural transformation.

Economic operators must recognise that, alongside traditional acute hazards (corrosivity, flammability), the regulatory focus now also includes chronic and environmental risks (endocrine disruption, environmental mobility).

Main strategic points for 2026:

• “Stop the Clock” does not mean inaction: the 2028 deferral enables a cost-efficient transition, but the technical deadlines in 2026 (MOCS, digital labelling fundamentals, new hazard classes) are set in stone.
• PFAS compliance is a critical point: managing firefighting foams is a technical and legal task that goes beyond the level of Safety Data Sheets; the synergy between disaster management and environmental requirements is decisive.

The key to successful compliance in 2026 is applying the “Compliance by Design” principle: every new product development and market launch must be assessed from the outset in light of the new CLP hazard classes and the REACH restrictions (siloxanes, PFAS).

This proactive approach not only prevents regulatory fines but also provides a competitive advantage in the European market that prioritises sustainability.

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• SDS translation services
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Useful articles:

• Compass for Chemical Safety
• FAQ – Frequently asked questions and answers
• Regulatory change tracker