CLP 2026: new hazard classes for mixtures – SDS and labelling action points

MSDS-Europe – Safety data sheet knowledge base – CLP 2026: new hazard classes for mixtures – SDS and labelling action points

As a result of the amendment of the CLP Regulation (Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures), new hazard classes have entered into force.

While the process has already started for single substances, for manufacturers and importers of mixtures the relevant deadline is 1 May 2026.

What exactly does the 1 May 2026 deadline mean?

Transitional provision (very important in practice)

If a mixture has already been placed on the market before 1 May 2026, the Regulation still provides a “grace period” until 1 May 2028 during which the old classification/label may continue to be used. However, this does not remove the need to prepare, because the supply chain (SDSs, labels, customer expectations) will typically “force” updates earlier.

Why was it necessary to extend the CLP Regulation?

Within the Chemicals Strategy framework, the European Commission aims to provide a higher level of protection for human health and the environment.

Certain substances have properties that were not given a dedicated category in the previous classification system, so communication about them was not fully comprehensive.

The introduction of the new classes helps identify substances that are endocrine disruptors, persist in the environment, or may threaten drinking water resources.

New hazard categories

The new regulatory approach is structured around three main groups, all of which assess long-term effects on both human health and the environment.

Endocrine disruptors (ED)

These compounds interfere with the body’s endocrine (hormonal) system. They may disrupt growth, development, or reproductive processes.

The new system distinguishes between endocrine-disrupting effects on human health and on the environment.

Under CLP, ED is addressed in two areas:

Endocrine disruption for human health (Category 1–2),
Endocrine disruption for the environment (Category 1–2).

From a labelling perspective, EUH statements typically apply here (e.g. EUH380/EUH381 and EUH430/EUH431, depending on the category).

PBT and vPvB substances – Persistent, Bioaccumulative and Toxic

PBT (persistent, bioaccumulative and toxic) substances degrade slowly, accumulate in living organisms, and are toxic.

vPvB (very persistent and very bioaccumulative) denotes compounds that are extremely resistant to environmental degradation and significantly bioaccumulate in the food chain.

Typical “threshold logic” for mixtures:

If a mixture contains a component classified as PBT/vPvB at a concentration of ≥ 0.1% (w/w), the mixture’s classification may also be affected.

EUH statements to be shown on the label:

PBT (EUH440): Accumulates in the environment and living organisms including in humans.
vPvB (EUH441): Strongly accumulates in the environment and living organisms including in humans.

PMT and vPvM substances – Persistent, Mobile and Toxic

For PMT (persistent, mobile and toxic) and vPvM (very persistent and very mobile) substances, the greatest concern is “mobility”.

Because these substances degrade slowly and readily spread in the aquatic environment, they can reach drinking water sources, from which they are difficult to remove using conventional treatment processes.

Practical threshold for mixtures:

If a component classified as PMT/vPvM is present at a concentration of ≥ 0.1% (w/w), it may affect the mixture’s classification/labelling.

Typical EUH statements on the label:

PMT (EUH450): Can cause long-lasting and diffuse contamination of water resources.
vPvM (EUH451): Can cause very long-lasting and diffuse contamination of water resources.

The introduction of PMT/vPvM classes also represents a paradigm shift for water authorities and drinking water protection, as CLP classification will directly provide a basis for restrictions under the Water Framework Directive.

Which sections of the safety data sheet are affected by the change?

Updating the classification of mixtures modifies the content of safety data sheets (SDSs) at several points:

Section 1 (Identification):
For mixtures, identifiers and—where relevant—UFI management may be linked to the changes.

Section 2 (Hazard identification / classification):

This is where the new hazard classes, the related supplemental hazard statements (EUH statements) and—given the absence of new pictograms—the required signal words (Danger/Warning) must be indicated.

Section 3 (Composition/information on ingredients):

Ingredient data must include the new classifications where they meet the relevant concentration limits.

In practice, this is where new ingredient classifications, thresholds, and the mixture classification logic are “decided”.

Our series on the SDS compilation process highlights in several places the role of concentration limits, specific concentration limits, and other factors.

Sections 11 and 12 (Toxicological and ecological information):

Detailed information must be provided on endocrine-disrupting properties, as well as PBT/vPvB and PMT/vPvM characteristics.

Notes:

Special attention should be paid to the consistency of Sections 11 and 12 with the classification (Section 2).

Statements that automatic SDS “generation” using software may be risky due to the new, case-specific assessment criteria (e.g. literature data on endocrine effects) are professionally well founded. Classification under CLP 2023/707 cannot always be derived purely by calculation if reliable test data for the new endpoints are not available.

Labelling: what changes in practice?

Key practical message:

For the new classes, hazard communication in many cases is provided via EUH statements and a signal word (Danger/Warning).

For everyday labelling questions (dimensions, layout, mandatory elements), our practical overview of CLP labelling and our article New CLP rules for online shops: labelling and advertising are useful references.

Typical challenges

1. Lack of supplier data

The most common problem is missing information coming from the supplier chain.

In many cases, safety data sheets for raw materials do not yet include the new classification, which makes it difficult to classify the finished product (mixture) accurately.

A new mixture placed on the market after 1 May 2026 must already be classified in accordance with the new rules. However, raw material manufacturers supplying the mixture’s components (if they supply a substance that is “already on the market”) are allowed to wait until 1 November 2026 to reclassify.

Consequence: Between May and November 2026, a mixture formulator may be legally obliged to classify the final product for the new hazards (e.g. ED), while their supplier has not yet provided the relevant data in the safety data sheet.

Solution: Market operators must proactively communicate with their suppliers and cannot wait for the final legal deadlines.

2. Misinterpretation of thresholds and the “0.1% rule”

For the new categories, specific concentration limits apply that determine when an ingredient must be considered for classification of the mixture.

Category 1 (ED HH 1 / ED ENV 1): If the concentration of the ingredient in the mixture reaches or exceeds 0.1%, the mixture must also be classified in Category 1.
Category 2 (ED HH 2 / ED ENV 2): The classification obligation applies only at ≥ 1% concentration.

Important!

If a mixture contains a Category 2 (suspected) endocrine disruptor at a concentration of ≥ 0.1% (w/w), the mixture itself does not need to be classified as hazardous on this basis, BUT the safety data sheet must be made available to professional users upon request.

3. Failure to update PCN / UFI

If the mixture’s hazard profile or composition changes, the existing PCN notification must be updated, and a new UFI may also be needed to identify the changed composition.

Practical help:

“Useful” PCN notification overview
UFI essentials
Comprehensive PCN/UFI service (notification, training, UFI management)

Application deadlines and transitional arrangements

The most critical point of compliance checking is interpreting the deadlines correctly.

The legislator introduced a complex, staged system that distinguishes between substances and mixtures, and between new products and those already on the market.

Substances:

Deadlines are set out in ECHA and Commission measures:

New substances: those first placed on the market after 1 May 2025 must apply the new rules immediately.

Substances already on the market: those already on the market before this date are granted a transitional period until 1 November 2026.

Mixtures:

For mixtures, the deadlines are later, reflecting that reclassification of the constituent substances is a time-consuming process.

New mixtures: those first placed on the market after 1 May 2026 must comply with the new classification.

Mixtures already on the market: “on-the-shelf” products may be relabelled and reclassified until 1 May 2028.

Practical preparation

By the 1 May 2026 deadline, mixtures already on the market must be reviewed.

It is recommended to follow these steps:

Portfolio inventory: list every manufactured/imported mixture and each packaging variant.

Communication with suppliers: request updated safety data sheets for raw materials and mixtures.

Review of classification: perform calculations in line with the new CLP rules based on the available data.

Update SDSs and labels: where the classification of raw materials changes, amend the mixture SDS as necessary and review the product label accordingly.

Related professional articles:

In brief

What exactly does the 1 May 2026 deadline mean for mixtures?

From 1 May 2026, the classification and labelling of mixtures must also take the new CLP hazard classes (e.g. ED, PBT/vPvB, PMT/vPvM) into account where warranted by the mixture’s composition. In practice, this means checking—and in many cases updating—the SDS and the label.

Which products are most affected by the change?

Primarily those mixtures that contain ingredients with endocrine-disrupting properties, or that fall under PBT/vPvB or PMT/vPvM classification. Typically affected products may include industrial auxiliaries, cleaning products, coatings, additives, and products used in applications involving contact with water.

Which parts of the SDS almost certainly need to be reviewed/updated?

Most often, the amendment affects SDS Section 2 (classification, label elements, EUH statements), Section 3 (composition and classification of ingredients), and Sections 11–12 (toxicological/ecotoxicological information). In addition, it is advisable to review the legal references in Section 15 as well.

What is the most common compliance error?

The most common issue is that suppliers’ SDSs for raw materials do not yet include the new classes, meaning the mixture classification cannot be reliably substantiated. Misunderstanding or ignoring concentration thresholds is also common, leading to incorrect classification and labelling.

Is updating the SDS enough, or do you also need to update the label/PCN?

If the mixture’s classification or hazard communication changes, the label will typically also need to be amended. In certain cases, changes may also affect PCN/UFI administration (especially where composition or hazard information changes), so it is advisable to include this as a control point in the preparation process.

Summary:

From 1 May 2026, the new CLP hazard classes are also mandatory for mixtures; therefore, classification, labelling and the SDS must be reviewed.

The change primarily strengthens more accurate communication of ED, PBT/vPvB and PMT/vPvM risks.

In practice, updates most commonly affect SDS Sections 2, 3 and 11–12. The key to preparation is collecting supplier data and applying the concentration thresholds correctly.

Where necessary, updating the PCN notification may also be required.

Related services:

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