CLP Rules for Webshops: Labelling and Advertising

MSDS-Europe – Compass for Chemical Safety – New CLP Rules for Webshops: Labelling and Advertising

 

The latest amendments to Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures (CLP Regulation) introduce significant changes for e-commerce and digital marketing.

The European Union aims to ensure that consumers enjoy the same level of protection in the digital environment as they do when purchasing in person.

 

Postponed deadlines: 1 January 2028 is the key date

While earlier drafts envisaged implementation in 2026, the final legislative outcome—Regulation (EU) 2025/2439—substantially revised the timeline.

The application of the most important obligations—including rules for online advertisements and distance-selling offers—has been moved to 1 January 2028. This postponement gives economic operators the opportunity to thoroughly prepare their IT systems and data management processes.

 

Conceptual distinction: “Advertisement” or “Offer”?

The basis for legal compliance is an accurate determination of the type of communication, which depends not on the platform itself, but on whether it enables a transaction.

Advertisement (CLP Article 48)

An advertisement is any communication whose primary purpose is to attract attention and promote the product, where the consumer cannot immediately conclude a contract.

Typical examples include Facebook ads, Google Display banners, and YouTube video ads.

Distance-selling offer (CLP Article 48a)

Any interface where the user is provided with the conditions necessary to make a purchasing decision and to initiate the conclusion of a contract.

In practice, the “watershed” is the presence of a transaction button (e.g., Add to cart, Order now).

This category includes product pages, category pages with quick-purchase functionality, and marketplace listings.

 

Mandatory content elements in advertisements

In visual advertisements for substances or mixtures classified as hazardous, the following elements must be displayed, where they also appear on the product label:

Especially important: For consumer sales, advertisements must include the following warning statement in English:

“Always follow the information on the product label.”

For non-visual advertisements (e.g., radio ads), the pictograms and the signal word may be omitted; however, the hazard statements and the mandatory warning statement above must still be communicated.

 

Expectations for webshop product pages

A distance-selling offer must include the label elements clearly and in a readily visible manner. Merely referring to a downloadable Safety Data Sheet or providing a small, illegible photo of the product label is not sufficient.

Mandatory data set (fields to be integrated into a PIM system)

The webshop database must store and display the following information in a structured format:

Placement recommendation: The hazard information block should be placed near the “Add to cart” button, in a location that remains clearly visible on mobile devices as well. The pictograms and the signal word should be visible by default.

 

Marketing “prohibited list”: Avoiding misleading claims

Pursuant to Article 25(4) and Article 48(3) of the CLP Regulation, it is prohibited to use claims in advertisements and product descriptions that contradict or downplay the product’s hazardous properties.

Prohibited expressions for hazardous products:

  • “non-toxic”, “harmless”, “not hazardous”
  • “environmentally friendly”, “eco”, “green”, “non-polluting”
  • “chemical-free”, “safe”, “child-friendly”

Instead, specific and substantiated claims may be used, such as “phosphate-free”, “solvent-free”, or “readily biodegradable surfactants (based on an OECD test)”.

 

How should economic operators prepare?

The cornerstone of compliance is up-to-date documentation. Data displayed in the webshop may be based solely on Section 2 of the Safety Data Sheet (SDS).

Recommended steps for the 2028 transition:

Audit: Review the product portfolio from the perspective of CLP classification.

Data management: Build structured data fields in the webshop engine and in the PIM system.

Documentation: Update missing or outdated Safety Data Sheets.

UX design: Integrate appropriate display components (hazard panels) into the interfaces.

 

If you need professional support to ensure regulatory compliance, we can help with the following services:

 

Frequently Asked Questions (FAQ)

Why did the previously communicated 2026 deadline change?

The original Regulation (EU) 2024/2865 designated several provisions as applicable from 1 July 2026. However, based on feedback from the chemical industry and the commercial sector, the legislator acknowledged that this date was not feasible due to the need to adapt IT systems and physically redesign labels. Therefore, the technical corrective Regulation (EU) 2025/2439 postponed the application of the most important obligations (advertising and distance selling) to 1 January 2028.

Is it mandatory to “copy” the entire physical label onto the webshop product page?

Under the Regulation, the label elements must be presented “in a readily visible manner” within the offer.

In practice, this does not necessarily mean a 1:1 graphical replication of the physical label, but rather a structured, clearly legible presentation of the essential hazard communication and identification elements (pictograms, signal word, H, P and EUH statements, and supplier details).

The objective is for the buyer to have all essential information at the moment the purchasing decision is made.

Is it sufficient if the Safety Data Sheet (SDS) can be downloaded from the product page?

No. The direction of the regulation is clear: the distance-selling offer must display the label elements directly on the interface in a readily visible manner.

While providing access to a downloadable Safety Data Sheet remains good and expected practice, it does not, on its own, replace the direct display of the mandatory elements on the webshop interface.

Do these rules also apply to B2B (business-to-business) sales?

Yes. The obligation relating to distance selling is not limited exclusively to the B2C (consumer) sector. Where sales are carried out through a means that enables communication between parties at a distance, the offer must include the specified elements.

However, there is a specific requirement for advertisements: for ads “addressed to the general public”, the additional warning statement is mandatory.

How exactly should the mandatory sentence be worded in consumer advertisements?

In English-language communications, use the following sentence: “Always follow the information on the product label.”.

It should be placed on the ad creative or at the beginning of the accompanying text, in a clearly legible manner.

Why can’t expressions such as “environmentally friendly” or “non-toxic” be used?

The CLP Regulation prohibits the use of any claims that contradict the product’s hazardous properties or suggest that the product is not hazardous.

Because terms such as “non-toxic” or “harmless” reduce user caution and create a misleading sense of safety, their use for products classified as hazardous breaches legal requirements. The same applies to general “green” messaging where it conflicts with the product’s CLP classification.

What should be done if the size limits of an advertising platform (e.g., Google Ads) do not allow the pictograms to fit?

In such cases, two solutions are recommended: either the given visual creative should not be run (compliance by design), or you should switch to a non-visual format (e.g., a plain text ad), where the Regulation allows omission of the pictograms and the signal word, but still requires the communication of the hazard statements (H statements).

Summary

By the 2028 deadline, webshops must undergo a comprehensive data collection and development process.

Key steps include auditing the product portfolio from a CLP perspective, updating Safety Data Sheets (SDS), and preparing IT systems (PIM/webshop engine) to store and display structured hazard information.

In marketing activities, it is essential to eliminate prohibited, misleading expressions and to integrate the required hazard communication elements into visual creatives.

 

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