ECHA REACH and CLP Report 2026: CLP New Hazard Classes, C&L Inventory and PCN UFI Enter a Stricter Compliance Phase

CLP New Hazard Classes and Harmonised Classification Are Reshaping Hazard Communication

The CLP Regulation (EC) No 1272/2008 governs the classification, labelling and packaging of substances and mixtures placed on the EU market. During 2021–2025, ECHA supported the continued development of harmonised classification and labelling under CLP. In this period, 202 substances were added or updated in Annex VI to CLP, including 63 substances added or updated as CMR category 1A/1B.

Harmonised classifications listed in Annex VI to CLP must be applied by manufacturers, importers, downstream users and distributors of the relevant substances and of mixtures containing those substances. This is a binding requirement, not a recommendation.

The regulatory impact can extend beyond CLP. Certain hazard classifications may trigger obligations or restrictions under product-specific EU legislation, particularly where substances are used in consumer products, workplace environments or other regulated applications.

The CLP framework has also expanded through Commission Delegated Regulation (EU) 2023/707, which amended CLP as regards new hazard classes and criteria. These include:

• endocrine disruptors for human health or the environment;

• persistent, bioaccumulative and toxic substances;

• very persistent and very bioaccumulative substances;

• persistent, mobile and toxic substances;

• very persistent and very mobile substances.

These CLP new hazard classes affect how companies assess hazards, document classification decisions and communicate risk information across the supply chain.

IUCLID, Guidance and Internal Classification Procedures Need to Keep Pace

ECHA updated relevant guidance and IT tools during the reporting period to support implementation of the revised CLP criteria. According to the report, IUCLID was updated in 2024 to align with CLP amendments, including data fields and validation rules for the new hazard classes.

Companies should therefore review whether their classification procedures, internal databases, IUCLID records, SDS templates and supplier data collection processes are aligned with the updated framework.

This is particularly important for companies handling:

• complex substances;

• UVCBs;

• polymers;

• specialty chemicals;

• hazardous mixtures with multiple upstream suppliers;

• products where hazard data are incomplete or based on weight-of-evidence approaches.

For practical implementation, companies may need support with EU CLP compliance, classification review, label assessment and SDS updates.

C&L Inventory on ECHA CHEM Increases Transparency

The revised Classification and Labelling Inventory was launched on ECHA CHEM on 20 May 2025, with the old Inventory decommissioned on 18 December 2025.

The revised C&L Inventory provides clearer and more accessible information, including:

• classifications with broad alignment;

• reduced duplication of information;

• improved contextual information;

• clearer visibility of applicable and upcoming harmonised classifications;

• display of new CLP hazard classes;

• classification update dates.

The C&L Inventory expanded from covering approximately 170,000 substances to 360,000 substances during 2021–2025, making it one of the largest public sources of hazard classification information based on the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

A further transparency change is expected from 1 July 2026, when ECHA will publish notifier names and reasons for different classifications. This will make inconsistent self-classifications more visible to authorities, customers, competitors and other supply chain actors.

For companies, the practical implication is that self-classification must be supported by clear technical reasoning. Where a company’s classification differs from other notifiers, the justification should be documented and defensible.

Companies required to submit classification and labelling information should also review whether an EU C&L Notification is required and whether the existing notification remains current.

Poison Centre Notification and UFI Requirements Are Now Fully in Force

The transition periods for Poison Centre Notifications (PCN) ended on 1 January 2025. From that date, national notification requirements no longer apply, and companies placing hazardous mixtures within the scope of CLP Annex VIII on the EU market must submit notifications in the harmonised format and include the Unique Formula Identifier (UFI) on the label.

During 2021–2025, industry submitted around 12 million notifications for hazardous mixtures through ECHA’s submission tool. From January 2025, EU inspectors also launched a six-month pilot project to check notifications for hazardous mixtures, including whether labels and, where needed, Safety Data Sheets are consistent with the submitted harmonised notifications.

For companies supplying hazardous mixtures, PCN compliance should not be treated as a standalone submission task. The UFI, formulation, product identifier, SDS, label, target market and notification content must remain consistent throughout the product lifecycle.

Companies placing hazardous mixtures on the EU market should review their EU UFI Generation and Poison Centre Notification (PCN) arrangements, especially where formulations, suppliers, private labels or distribution markets have changed.

Impact & Actionable Advice for Multinational Companies

ECHA’s 2026 report shows that CLP compliance is becoming more transparent and more closely connected with enforcement. Companies should strengthen internal control over classification, labelling and notification data.

1. Reassess Substance and Mixture Classifications

Companies should review whether existing classifications reflect:

• current Annex VI harmonised classifications;

• the new CLP hazard classes;

• updated supplier data;

• available toxicological and ecotoxicological evidence;

• C&L Inventory information on ECHA CHEM;

• relevant changes introduced by the 2023 and 2024 CLP revisions.

2. Audit SDS and Label Consistency

Safety Data Sheets and labels should be checked against:

• current CLP classification;

• Annex VI harmonised classification entries;

• UFI information;

• PCN submissions;

• product composition;

• language and market-specific requirements in relevant EU Member States.

Any inconsistency may create enforcement risk, particularly for hazardous mixtures. Where updates are needed, REACH24H’s Global GHS/SDS/MSDS/Label service can support SDS authoring, SDS review, label verification and multilingual hazard communication.

3. Strengthen UFI and Formulation Control

ECHA has emphasised the importance of correct UFI management, including the principle of “one UFI – one composition”. Companies should establish controls for:

• formulation changes;

• product variants;

• private label products;

• toll manufacturing;

• rebranding and relabelling;

• multi-country EU notifications;

• distributor and importer arrangements.

4. Monitor C&L Inventory and CLH Developments

Companies should monitor ECHA CHEM, the C&L Inventory, CLH intentions, Annex VI updates and relevant substance group developments. Early monitoring helps companies prepare for SDS updates, label changes, customer communication and possible downstream regulatory consequences.

5. Document Classification Justifications

As classification differences become more visible, companies should maintain clear technical documentation supporting their classification decisions. This is especially important where:

• self-classification differs from other notifiers;

• data are incomplete;

• read-across or weight-of-evidence approaches are used;

• the substance may fall within a new hazard class;

• the classification affects mixture classification or PCN obligations.

How REACH24H Can Help

REACH24H supports global companies with practical CLP compliance solutions for substances and mixtures placed on the EU market. Our services include:

• EU CLP Compliance Support: classification, labelling and packaging compliance assessment under CLP;

• EU C&L Notification: C&L notification assessment, preparation and submission support;

• EU UFI Generation and Poison Centre Notification (PCN): UFI generation, PCN preparation, submission and post-notification update support;

• Global GHS/SDS/MSDS/Label Services: SDS authoring, SDS review, label compliance and multilingual hazard communication;

• One-Stop Compliance Solution for Exporting Chemical Products to the EU: integrated support for REACH, CLP, PCN, SCIP, SVHC and EU chemical market access requirements.

As CLP compliance becomes more transparent and enforcement-focused, companies should verify whether their classification, SDS, labels, UFI and PCN submissions remain aligned.