CLP label: what a hazardous chemical product must show, on the pack and in the listing

CLP stands for classification, labelling and packaging. It is Regulation (EC) No 1272/2008Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027The whole regulationClick opens the law on the EU Publications Office., the EU law that decides whether a chemical product counts as hazardous and, if it does, what its label and its pack must look like. It covers substances and mixtures. A cleaner, a paint, a glue or a blended diffuser oil is usually a mixture: “a mixture or solution composed of two or more substances” (Art. 2(8)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 8Click opens the article on EUR-Lex.). A single essential oil is usually a substance (Art. 2(7)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 7Click opens the article on EUR-Lex.). A substance’s label identifies it by a chemical name and, where one exists, an identification number such as its CAS number (Art. 18(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 18, paragraph 2Click opens the article on EUR-Lex.). A substance needs no poison centre submission and no UFI: those are for mixtures (Annex VIII, Part A, section 2.1).

The changes you may have read about come from a 2024 revision. Some have applied since 1 July 2026. The rest start on 1 January 2027 and 1 January 2028. The dates are in the table under “When each change applies”.

Which products need a CLP label

The label duty covers “a substance or mixture classified as hazardous and contained in packaging” (Art. 17(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 17, paragraph 1Click opens the article on EUR-Lex.). Classification comes first. The manufacturer, the importer or the downstream user classifies the product before it is placed on the market (Art. 4(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 1Click opens the article on EUR-Lex.). A distributor may use the classification from its supplier (Art. 4(5)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 5Click opens the article on EUR-Lex.). A downstream user may too, “provided that they do not change the composition of the substance or mixture” (Art. 4(6)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 6Click opens the article on EUR-Lex.); once you blend, dilute or mix it into something else, you classify the result yourself. Every supplier then makes sure the product is labelled and packed before it is placed on the market (Art. 4(4)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 4Click opens the article on EUR-Lex.), and suppliers in a chain cooperate to get it right (Art. 4(9)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 9Click opens the article on EUR-Lex.).

So the product type does not decide it. A cleaner, a paint, a glue or a diffuser oil needs the full CLP label when its classification says it is hazardous.

A biocide adds label rules in two cases. A biocidal product, such as a disinfectant, is a substance or mixture like any other here: it needs the CLP label when it is classified as hazardous (Art. 4(4)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 4Click opens the article on EUR-Lex.). The Biocidal Products Regulation adds its own label and advertising rules whether it is classified or not (Art. 69Regulation (EU) No 528/2012, Biocidal Products Regulation (consolidated text of 19 August 2026)Article 69Click opens the article on EUR-Lex., Art. 72Regulation (EU) No 528/2012, Biocidal Products Regulation (consolidated text of 19 August 2026)Article 72Click opens the article on EUR-Lex.). A finished object treated with a biocide, such as a textile with an anti-odour finish, is an article, and CLP labels an article only if it is explosive (Art. 4(8)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 8Click opens the article on EUR-Lex., Annex I, section 2.1). The same regulation gives it a biocide label when you claim a biocidal effect, such as “antibacterial”, or the active substance’s approval requires one (Art. 58(3)Regulation (EU) No 528/2012, Biocidal Products Regulation (consolidated text of 19 August 2026)Article 58, paragraph 3Click opens the article on EUR-Lex.). An object whose main purpose is to kill or control organisms is a biocidal product, not a treated article (Art. 3(1)(a)Regulation (EU) No 528/2012, Biocidal Products Regulation (consolidated text of 19 August 2026)Article 3, paragraph 1, point (a)Click opens the article on EUR-Lex.).

A mixture that is not classified can still need a CLP label. “A mixture referred to in Part 2 of Annex II that contains any substance classified as hazardous shall not be placed on the market, unless it is labelled in accordance with Title III” (Art. 4(7)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 7Click opens the article on EUR-Lex.). Where it holds a substance classified as a skin sensitiser at 0.1% or more, or 0.01% or more for sub-category 1A, the label carries EUH208: “Contains (name of sensitising substance). May produce an allergic reaction” (Annex II, section 2.8, with Table 3.4.6 of Annex I). A fragrance oil or a diffuser oil can meet this. The label then also carries the product identifier and “the name, address and telephone number of the supplier of the mixture” (Art. 25(6)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 25, paragraph 6Click opens the article on EUR-Lex.), and names the supplier established in the EU (Art. 4(11)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 11Click opens the article on EUR-Lex.). A mixture of this kind that is not intended for the general public also carries EUH210, “Safety data sheet available on request”, when it holds a sensitiser at or above that limit, or another listed substance such as a carcinogen category 2 or a reproductive toxicant at 0.1% or more (Annex II, section 2.10). The sheet itself is set out in safety data sheet requirements. The other special rules for such mixtures are in Annex II, Part 2.

CLP does not apply to these products in their finished state, for the final user: cosmetics, medicinal products, veterinary medicinal products, medical devices that are invasive or used in direct contact with the body, and food and feed (Art. 1(5)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 1, paragraph 5Click opens the article on EUR-Lex.). It does not apply to goods under customs supervision in temporary storage, a free zone or transit, as long as they are not processed (Art. 1(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 1, paragraph 2Click opens the article on EUR-Lex.). Finished objects, which CLP calls articles, are labelled under CLP only if they are explosive (Art. 4(8)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 8Click opens the article on EUR-Lex., Annex I, section 2.1).

What goes on the label

The pictograms, signal word, hazard statements and precautionary statements sit together on the label (Art. 32(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 32, paragraph 1Click opens the article on EUR-Lex.). Where the pack itself shows every element clearly, no separate label is needed (Art. 31(5)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 31, paragraph 5Click opens the article on EUR-Lex.). Where a pack is too small or so shaped that the label cannot fit in the languages required, Annex I, section 1.5.1 sets how the elements are given instead (Art. 29(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 29, paragraph 1Click opens the article on EUR-Lex.).

Fold-out labels, since 1 July 2026. A label may fold out (Art. 31(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 31, paragraph 1Click opens the article on EUR-Lex.). Its front page carries at least the supplier’s name, address and phone number, the nominal quantity, the product identifiers and signal words in every language used inside, the pictograms, the UFI unless it is on the inner packaging, a pointer to the full safety information inside, and a code for each language inside. The inner pages carry every other label element, grouped by language. The back page repeats the front page, without the language codes (Art. 31(1a)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 31, paragraph 1aClick opens the article on EUR-Lex., Annex I, section 1.2.1.6).

Digital labels, since 1 July 2026. The physical label stays compulsory; a digital label may be added to it (Art. 34a(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 34a, paragraph 1Click opens the article on EUR-Lex.). Only supplemental information under Art. 25(3)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 25, paragraph 3Click opens the article on EUR-Lex. may be given on the digital label alone (Art. 34a(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 34a, paragraph 2Click opens the article on EUR-Lex., Annex I, section 1.6). A code that links to the digital label goes on the physical label or next to it, with the words “More hazard information available online” where anything is online only (Art. 31(1b)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 31, paragraph 1bClick opens the article on EUR-Lex.). The digital label shows every label element in one place, is searchable, stays online for at least 10 years, is free, needs no registration, app or password, and is no more than two clicks away (Art. 34b(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 34b, paragraph 1Click opens the article on EUR-Lex.). You may not track its readers beyond what is strictly needed to show it (Art. 34b(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 34b, paragraph 2Click opens the article on EUR-Lex.). Anyone who asks gets the online-only elements another way, free of charge and without having to buy (Art. 34a(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 34a, paragraph 2Click opens the article on EUR-Lex.).

How big the label and its text must be

The label sizes apply now and do not change in 2028 (Annex I, section 1.2.1.4, Table 1.3). The size of each pictogram in the same table, and the rule that it covers at least one fifteenth of the label area, are in CLP hazard pictograms.

From 1 January 2028 the text on the label must also be printed in black on a white background, with at least 120% of the font size between lines, in a single easily legible font without serifs, with letter spacing that keeps it legible. On an inner pack of 10 ml or less, the most critical statement may be set smaller if it stays easily legible and the outer pack meets Art. 17Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 17Click opens the article on EUR-Lex. (Annex I, section 1.2.1.5, added by Annex I, point 3, of Regulation (EU) 2024/2865Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)The whole regulationClick opens the law on the EU Publications Office.). Until then the rule is that the label elements are clearly and indelibly marked, stand out from the background and are easy to read (Art. 31(3)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 31, paragraph 3Click opens the article on EUR-Lex.).

What your listing must show

Until 31 December 2027. An advertisement for a hazardous mixture, or for a mixture carrying the special statements of Art. 25(6)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 25, paragraph 6Click opens the article on EUR-Lex., that lets a member of the general public conclude a purchase without first seeing the label names “the type or types of hazard indicated on the label” (Art. 48(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 48, paragraph 2Click opens the article on EUR-Lex.). An advertisement for a hazardous substance names its hazard classes or categories (Art. 48(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 48, paragraph 1Click opens the article on EUR-Lex.).

From 1 January 2028. Two new rules apply (Art. 2(3a)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 2, paragraph 3aClick opens the article on EUR-Lex.):

• Online offers. “When substances or mixtures are placed on the market through distance sales, the offer shall clearly and visibly indicate the label elements referred to in Article 17” (new Article 48a, inserted by Art. 1(27)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 1, point 27Click opens the article on EUR-Lex.). The listing then shows what the pack shows: the supplier, the quantity, the product identifiers, the pictograms, the signal word, the hazard statements, the precautionary statements and the supplemental information.
• Advertisements. Any advertisement for a hazardous substance or mixture, or for a mixture carrying the special statements of Art. 25(6)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 25, paragraph 6Click opens the article on EUR-Lex., shows the hazard pictograms, signal words, hazard statements and supplemental EUH statements. One for sale to the general public also states “Always follow the information on the product label.” A non-visual advertisement, such as a radio spot, may leave out the pictograms and the signal words. No advertisement may carry a statement banned on the label, such as “non-toxic” (new Article 48, replaced by Art. 1(26)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 1, point 26Click opens the article on EUR-Lex.).

The revision explains the difference: an advertisement promotes a product, while an offer is an invitation to conclude a purchase contract, so an offer carries more (recital 37 of Regulation (EU) 2024/2865Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)The whole regulationClick opens the law on the EU Publications Office.). The same recital says the compliance-by-design duties of online marketplaces under Article 31Regulation (EU) 2022/2065, Digital Services ActArticle 31Click opens the article on EUR-Lex. of the Digital Services Act apply to the display of these label elements. Marketplaces must therefore give you a way to show them.

Who carries each duty

CLP puts its duties on a “supplier”: any manufacturer, importer, downstream user or distributor placing a substance or a mixture on the market (Art. 2(26)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 26Click opens the article on EUR-Lex.). Placing on the market means supplying it to anyone else, paid or free, and import counts as placing on the market (Art. 2(18)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 18Click opens the article on EUR-Lex.).

When a UFI and a poison centre submission are needed

Importers and downstream users that place on the market a mixture classified as hazardous for its health or physical effects send information on it to the bodies each EU country appoints under Art. 45(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1Click opens the article on EUR-Lex., often called poison centres (Annex VIII, Part A, sections 2.1 and 3.1). Substances are not covered. Until 31 December 2026 the duty rests on that wording of Annex VIII, which the consolidated text of 1 July 2026 prints. From 1 January 2027 it sits in Art. 45(1b)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1bClick opens the article on EUR-Lex., distributors join it (Art. 45(1c)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1cClick opens the article on EUR-Lex.), and a country may appoint ECHA, the European Chemicals Agency, as its body (Art. 45(1a)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1aClick opens the article on EUR-Lex.; all three from Reg. 2024/2865, Art. 1, point (24)(b)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 1, point 24, point (b)Click opens the article on EUR-Lex., with its date in Art. 2(3)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 2, paragraph 3Click opens the article on EUR-Lex.).

• Before you sell, in every country you sell in. The submission goes to the body in each EU country where the mixture is placed on the market, in that country’s official language unless it allows another, in the XML format ECHA provides free of charge (Annex VIII, Part A, sections 3.1 and 3.3).
• Since 2021. Mixtures for consumer and professional use have been covered since 1 January 2021, mixtures for industrial use since 1 January 2024 (Annex VIII, Part A, sections 1.1 to 1.3).
• The UFI. The unique formula identifier links your submission to the label. You create it with ECHA’s tool, free of charge, and print it in the supplemental information (Art. 25(7)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 25, paragraph 7Click opens the article on EUR-Lex.). How to make it, where it goes and when a new one is needed is in UFI code. Who submits, what a submission holds and the portal are in poison centre notification.
• Scent ranges. One group submission can cover several mixtures only “where all the mixtures in a group have the same classification for health and physical hazards” (Annex VIII, Part A, section 4.1). Within that, the mixtures may differ only in their perfume, provided the differing perfumes total no more than 5% of each (section 4.3).
• Distributors, from 1 January 2027. A distributor that sells the mixture into another EU country, or rebrands or relabels it, submits too, unless it can show the body already received the same information (Art. 45(1c)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 45, paragraph 1cClick opens the article on EUR-Lex.).

What the packaging must meet

Every pack of a hazardous product is built so its contents cannot escape, with materials the contents cannot damage, strong enough for normal handling, and resealable without leaks where it has a replaceable cap (Art. 35(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 35, paragraph 1Click opens the article on EUR-Lex.). A pack for the general public may not have a shape or design likely to attract children or mislead consumers, and may not look like food, feed, a medicine or a cosmetic (Art. 35(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 35, paragraph 2Click opens the article on EUR-Lex.).

Both rows are Annex II, Part 3, sections 3.1 and 3.2, applied by Art. 35(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 35, paragraph 2Click opens the article on EUR-Lex..

Refill stations, since 1 July 2026. A hazardous product may be sold to consumers and professional users by refill only under the conditions of Annex II, section 3.4 (Art. 35(2a)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 35, paragraph 2aClick opens the article on EUR-Lex.). The station carries the product’s label. Risks to people, children above all, and to the environment are kept low, and children are kept from using the station. The supplier is on site for help at the moment of refill, and staff are trained. Each refilled pack is labelled and packed as CLP requires. Products classified for acute toxicity, skin corrosion category 1, serious eye damage category 1, respiratory or skin sensitisation, aspiration hazard, carcinogenicity, mutagenicity, reproductive toxicity, specific target organ toxicity, flammable gases, flammable liquids categories 1 and 2, flammable solids, endocrine disruption, or the persistent, bioaccumulative and toxic, very persistent and very bioaccumulative, persistent, mobile and toxic, or very persistent and very mobile properties may not be refilled at all (Annex II, section 3.4, point (k)).

When a label must be updated

A label is not replaced on a schedule. It changes when the product’s classification or labelling changes.

• Until 31 December 2027. Where the new hazard is more severe, or new supplemental elements are required, the supplier updates the label without undue delay. Any other change is made within 18 months (Art. 30Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 30Click opens the article on EUR-Lex.).
• From 1 January 2028. A new hazard class, a more severe classification or new supplemental information: without undue delay, and no later than 6 months after the supplier obtains or receives the results of the new evaluation. Any other change: no later than 18 months. Where a change comes from a harmonised classification set by a delegated act, the date in that act applies (new Article 30, replaced by Art. 1(14)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 1, point 14Click opens the article on EUR-Lex.).

When each change applies

The original 2024 text set 1 July 2026 for the advertisement and online offer rules and 1 January 2027 for the label format. Regulation (EU) 2025/2439Regulation (EU) 2025/2439, deferring dates of the 2024 CLP revisionThe whole regulationClick opens the law on the EU Publications Office. of 26 November 2025 moved both, and the relabelling deadlines, to 1 January 2028. Its reason: the Commission had proposed to simplify these rules again, and business needed time for the changes that proposal envisages (recital 2 of Regulation (EU) 2025/2439Regulation (EU) 2025/2439, deferring dates of the 2024 CLP revisionThe whole regulationClick opens the law on the EU Publications Office.). That proposal, COM(2025) 531 of 8 July 2025, is not law. On 2026-10-05 the EU Publications Office register listed no act adopted on it, and its consolidated CLP text of 1 January 2027 lists no amendment made by it.

The EU’s consolidated CLP text dated 1 July 2026 prints Articles 48 and 48a in their new wording. A consolidated text is “a documentation tool” with “no legal effect”, in its own words; Regulation (EU) 2025/2439Regulation (EU) 2025/2439, deferring dates of the 2024 CLP revisionThe whole regulationClick opens the law on the EU Publications Office. is what binds. The consolidated text dated 1 January 2027 prints Articles 30 and 48 as they apply until the end of 2027. It also prints Articles 1(1)(f), 18(3)(b), 45(1a) to (1c) and 45(3), and Annex VIII, Part A, sections 1 and 2, in the wording that applies from 1 January 2027. Until then the wording in force for those provisions is in the consolidated text of 1 July 2026.

What happens if you do nothing

A substance or mixture that does not comply with CLP may not be placed on the market (Art. 4(10)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 10Click opens the article on EUR-Lex.). Each EU country runs official controls to keep such products off its market, and follows up complaints and reports (Art. 46(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 46, paragraph 1Click opens the article on EUR-Lex., Art. 46(1a)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 46, paragraph 1aClick opens the article on EUR-Lex.). Each country also sets the penalties, which must be “effective, proportionate and dissuasive” (Art. 47Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 47Click opens the article on EUR-Lex.).

CLP is on the list of Union harmonisation legislation in Annex I to Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. (point 25). So market surveillance authorities can require you to bring the product into compliance, stop it being sold, withdraw or recall it, or destroy it (Art. 16(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.). At the border, customs suspend the release of a product that is “not marked or labelled in accordance with the Union law applicable to it” (Art. 26(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 26, paragraph 1Click opens the article on EUR-Lex.).

What the law leaves open

• Whether a listing is an “advertisement” before 2028. Today’s rule covers an advertisement that lets the public buy without first seeing the label (Art. 48(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 48, paragraph 2Click opens the article on EUR-Lex.). The 2024 revision itself says the current text “does not explicitly refer to offers in general or to distance sales offers” (recital 37 of Regulation (EU) 2024/2865Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)The whole regulationClick opens the law on the EU Publications Office.). In our reading, a product page with a buy button is exactly that kind of advertisement, so name the hazard types on it now.
• Who the EU supplier is for a parcel sent from outside the EU straight to a consumer. Art. 4(11)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 11Click opens the article on EUR-Lex. requires a supplier established in the EU, identified on the label. CLP’s importer is established in the EU and responsible for import (Art. 2(17)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 17Click opens the article on EUR-Lex.); a consumer buying for personal use is not a supplier. No article names who fills that role on this route. Meanwhile, sell hazardous products into the EU only through an EU business that is named on the label and takes on the CLP duties.
• Stock placed on the market during 2027. Art. 61(8)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 61, paragraph 8Click opens the article on EUR-Lex. still gives stock placed on the market before 1 January 2027 until 1 January 2029 to meet the new label format, while the format itself now applies from 1 January 2028. Regulation (EU) 2025/2439Regulation (EU) 2025/2439, deferring dates of the 2024 CLP revisionThe whole regulationClick opens the law on the EU Publications Office. changed the dates of application and left that paragraph as it was. What happens to stock labelled in the old format and placed on the market during 2027 is not stated. Nor is it settled whose placing on the market counts for stock placed before 1 January 2027. Each supply to someone else is a placing on the market (Art. 2(18)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 18Click opens the article on EUR-Lex.), so a reseller’s own later sale may count as a new one; no article says whether the first placing or the reseller’s own date decides.
• Candles and wax melts. CLP labels substances and mixtures, and among finished objects only explosive ones (Art. 4(8)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 8Click opens the article on EUR-Lex.). An article is an object whose shape, surface or design decides its function more than its chemical composition does (Art. 2(9)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 9Click opens the article on EUR-Lex.). No article of CLP names candles. The fragrance oil you buy to make them is a substance or a mixture, and its safety data sheet gives its classification. Until this is settled, label a candle or wax melt as a mixture where it is classified as hazardous, or where it holds a substance that triggers EUH208 or another Annex II, Part 2 statement (Art. 4(7)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 7Click opens the article on EUR-Lex., Art. 25(6)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 25, paragraph 6Click opens the article on EUR-Lex.). That label meets CLP if CLP applies.
• How a product that needs no CLP label names its EU supplier. Art. 4(11)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 11Click opens the article on EUR-Lex. reads: “A substance or a mixture shall not be placed on the market unless a supplier established in the Union, which shall be identified on the label, … fulfils the requirements set out in this Regulation”. It is not limited to hazardous products. A mixture that is not classified and holds no Annex II, Part 2 substance has no CLP label duty, and no article says where the EU supplier is identified then. A mixture labelled with EUH208 or another Annex II, Part 2 statement has a CLP label (Art. 25(6)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 25, paragraph 6Click opens the article on EUR-Lex.), so name the EU supplier on it.