The European Commission has notified the WTO of a substantial draft CLP amendment aligning the regulation with UN GHS revisions 8 to 11. Comments close 16 October 2026, and adoption is expected in the fourth quarter of the year. This isn’t a routine annual tidy-up. It’s a rewrite that will reach the classification logic and labelling rules behind every safety data sheet you touch.
What’s actually in the draft
- A new “chemicals under pressure” hazard class. A genuinely new classification category, not an amendment to an existing one.
- Non-animal test methods for health hazard classification. A shift in accepted methodology, not just updated thresholds.
- Revised criteria for skin-sensitising mixtures. Existing mixtures could see their classification change under the new criteria, even without any change to their composition.
- Alignment of metal and metal compound classification with aquatic toxicity provisions. Relevant to anyone working with metal-based products, coatings or finishing processes.
- Rationalised precautionary statements. A cleanup of the statement set itself, which sounds minor but touches label text across the board.
Why this reaches further than a typical CLP update
Most CLP changes affect specific substances or a defined list. This one changes some of the underlying classification rules themselves, which means the effect isn’t confined to a substance list you can simply check against. It’s the kind of change that can shift a classification, and therefore a label and an SDS, even for products that haven’t changed at all. If you’ve read our earlier post on safety data sheets quietly drifting out of date without anyone noticing, this is precisely the sort of underlying-framework change that causes it.
What to watch for specifically
- Whether any of your products or raw materials fall under the new chemicals-under-pressure hazard class, particularly aerosols, pressurised containers or gas-containing products.
- Whether the revised skin-sensitising mixture criteria change the classification of any formulated products, not just single substances.
- Whether the metal and aquatic toxicity alignment affects metal-heavy products, surface treatments or coatings in your range.
- Whether any precautionary statements on your current labels are among those being rationalised, which could mean a wording change even where the underlying hazard classification hasn’t moved.
What to do now
This is still a draft, and comments don’t close until 16 October, so there’s nothing to change on a label today. But treat this as the moment to understand where your exposure sits, rather than waiting for entry into force to find out. Earmark a proper SDS and label review once adoption is confirmed, and make sure whoever owns that process internally knows this is coming.
How we can help
We help clients work out in advance which products are likely to be affected by a classification rewrite like this one, and get SDS and label reviews scheduled for the moment it’s confirmed, rather than scrambling once it’s already law. Get in touch if you’d like a head start on scoping the impact for your product range.
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