News Brief
On December 3, 2025, the Official Journal of the European Union officially published Regulation (EU) 2025/2439, introducing urgent amendments to the 2024 revision of the Regulation on Classification, Labelling and Packaging of Substances and Mixtures (CLP Regulation), (EU) 2024/2865.
The original amendment, (EU) 2024/2865, introduced several new compliance obligations for companies, including requirements related to label format, advertising and promotion, distance selling, and fuel station labelling, among other areas.
While these provisions aim to enhance the transparency of chemical safety information, their complex implementation and high costs have imposed significant compliance requirements and packaging modification challenges on the chemical, cosmetics, and daily chemical industries.
In response to industry concerns, the EU has decided to postpone the mandatory implementation date of these new regulations significantly, from 2026 to January 1, 2028.
This major adjustment directly responds to the core recommendations of The Future of European Competitiveness Report (Draghi Report), which focuses on regulatory simplification and economic competitiveness. It reflects the EU's efforts to balance regulatory requirements with industrial realities and provides the global chemical supply chain with valuable buffer time.
Core Amendments: Which Requirements Have Been Postponed?
The new regulation, (EU) 2025/2439, primarily adjusts the effective dates of four key provisions in (EU) 2024/2865 (label format, advertising standards, distance selling obligations, and fuel station labelling), uniformly postponing their mandatory implementation to January 1, 2028.
Label Format and Readability Requirements
Amendment Details: All labels must meet specific minimum font size requirements (e.g., text height of at least 1.4mm for packaging under 3 liters), and line spacing must be at least 120% of the font size. This forces many companies to redesign packaging moulds.
Impact on Compliance: The two-year postponement allows companies to naturally deplete existing packaging material inventories, avoiding the waste of tens of thousands of packaging units. While the label format requirements are delayed, the provision in (EU) 2024/2865 permitting the use of digital labelling has not been repealed. Companies should use this additional two-year window to adopt a combination of physical labels + digital labels to address the dual challenges of minimum font size and information volume.
Advertising and Promotional Language Standards
Amendment Details: The use of misleading terms such as non-toxic, non-harmful, and ecological in hazardous chemical advertisements is prohibited. Additionally, all advertisements (including online pop-ups) must display hazard pictograms and signal words.
Impact on Compliance: The two-year postponement provides companies with more time to clean up marketing materials and adjust market promotion strategies.
Distance Selling and Online Marketplace Obligations
Amendment Details: For distance selling within the EU (e.g., e-commerce platforms), complete label elements must be clearly displayed to consumers before purchase. Additionally, a supplier established in the EU must be responsible for product compliance.
Impact on Compliance: The two-year delay gives cross-border e-commerce operators more time to improve product page information and transition to integrated compliance management for labels, advertising, and e-commerce.
Fuel Stations and Bulk Fuel Labelling
Amendment Details: Fuel pump nozzles and portable containers at fuel stations must display detailed label information, including the supplier name and UFI (Unique Formula Identifier).
Impact on Compliance: Recital (3) of (EU) 2025/2439 explicitly states in its preamble that the Commission has found the requirement for fuel stations to label supplier name and UFI to be impractical, costly, and of little benefit to health protection. The Commission plans to amend these requirements in the future to remove unnecessary fields. This postponement is intended to allow time for these amendments to take effect.
Continuing Risks: Requirements Not Postponed
Although some requirements, such as label format, have been postponed, companies must not assume that CLP compliance efforts can be entirely deferred.
It is important to note that (EU) 2025/2439 only postpones specific administrative provisions in (EU) 2024/2865, while other core scientific assessment obligations under the CLP Regulation remain on schedule
Classification and Assessment of Newly Introduced Hazard Categories
The new hazard categories introduced in (EU) 2024/2865 and previous amendments include:
Endocrine Disruptors (ED);
Persistent, Bioaccumulative, and Toxic Substances (PBT);
Persistent, Mobile, and Toxic Substances / Very Persistent and Very Mobile Substances (PMT/vPvM).
The classification standards and corresponding transition periods for these categories are unaffected by this postponement, and related assessments and compliance efforts must proceed as planned.
Poison Centre Notification (PCN)
Distributors and rebranding companies must closely monitor their applicable PCN transition deadlines to ensure that toxicological information related to their products is submitted to the European Chemicals Agency (ECHA) accurately and promptly.
Uncertainty Surrounding Simplification Proposals
The EU is advancing broader chemical regulation simplification initiatives (see COM(2025) 531 Document).
While the overall direction aims to reduce burdens on businesses, specific measuressuch as the potential removal of certain label elements or simplification of notification processesare still under discussion and have not yet been finalized into legislation.
Therefore, companies should closely monitor subsequent EU policy developments to adjust their compliance strategies in a timely manner.
Compliance Recommendations for Exporting to the EU
In light of the EU's regulatory revisions and adjustments, REACH24H recommends the following strategies for relevant companies:
Conduct Immediate Inventory Reviews: Verify whether the labels of existing inventory products comply with current CLP requirements.
Regulatory Technical Aspects: Continue advancing the screening of new hazardous components such as ED and PBT, as this is critical for market access qualification and cannot be delayed.
Corporate Planning Aspects: Tasks such as label layout adjustments, advertising language revisions, and website product page updates can be temporarily deprioritized.
Final Remarks
Although the mandatory implementation date of the new regulations has been postponed to January 1, 2028, supporting guidance documents are typically issued approximately 18 months before formal implementation (around mid-2026) to clarify technical details and implementation requirements.
Therefore, REACH24H recommends that companies reassess and update their compliance strategies by mid-2026 to ensure alignment with the latest regulatory expectations.
The introduction of (EU) 2025/2439 is a positive signal from EU regulators to the industryindicating a greater focus on the practicality of regulations and a commitment to finding a more pragmatic balance between public safety objectives and corporate competitiveness.
Now, a critical two-year buffer period has been provided. REACH24H advises companies to seize this opportunity to shift compliance efforts from reactive responses to proactive planning, as recommended by regulatory best practices, by conducting a systematic review of product labels, supply chain communications, and internal processes to prepare thoroughly for the new key milestone in 2028.
For more information and inquiries, please feel free to contact us at customer@reach24h.com.
