CLP labels under the microscope: what changes for chemical companies with the Simplification Regulation

In just over two years, CLP label formatting has been rewritten, suspended and rewritten again, putting pressure on regulatory departments at chemical companies and manufacturers of paints, coatings, adhesives, sealants and inks. Some businesses have already redesigned their labels in accordance with EU Regulation 2024/2865 and are now wondering whether they will have to do so again. In this article, we clarify the situation by starting with what the legislation requires today and in light of the Simplification Regulation expected by the end of the year.

Why the CLP label is back at the centre of attention

On 20 November 2024, Regulation (EU) 2024/2865 was published in the Official Journal, substantially changing the CLP labelling rules by introducing both new content requirements (what must appear on the label) and new formatting requirements (how the information must be presented). Only one year later, on 5 December 2025, the “Stop the Clock” Regulation (EU) 2025/2439 was published, postponing the application dates of the new formatting requirements. In parallel, the Simplification Regulation was already being developed: on 17 June 2026, the European Parliament and Council reached a provisional agreement, with publication of the final text expected in autumn 2026.

In essence, Regulation 2024/2865 has not been repealed: the content of the label remains unchanged, while the format is becoming more flexible. Those who worked on label content in 2025 were right to do so. Those who have already redesigned the layout anticipated an obligation that, to a large extent, will not arrive in exactly that form. This does not mean that the work was wasted, however: let us look at why in detail.

The Simplification Regulation: what changes in label formatting

The forthcoming text aims specifically to streamline the formatting requirements of CLP labels, helping chemical companies and formulators of paints, coatings, adhesives, sealants and inks that need to label complex mixtures. The main expected changes are:

Greater flexibility in formatting:

Black text on a white background will no longer be mandatory; it will be sufficient for the text colour to contrast with the background;

There will no longer be a minimum font size or defined line spacing: these will be at the supplier’s discretion, provided legibility is ensured;

The requirement to use a single sans-serif typeface remains.

Dimensional parameters for B2C labels: only for products intended for the general public will the minimum x-height be required to be 1.2 mm (0.9 mm where the packaging is 125 ml or less).

Relabelling timelines: in the event of a more severe classification or new supplementary elements required on the label, the label must be updated within 15 months and suppliers are required to cooperate in transmitting this information downstream through the supply chain.

How to prepare for the new rules without doing everything again: an operational checklist for paints, adhesives and sealants

As regards label format:

Labels already compliant with Regulation 2024/2865 (minimum size, 120% line spacing, etc.) do not necessarily need to be reworked: they will still meet the formatting requirements that the Simplification Regulation will introduce.

Labels not yet compliant with Regulation 2024/2865 can wait for publication of the Simplification Regulation and be adapted just once, in line with the final requirements. requirements. Existing labels will also benefit from broad transitional periods for using up stock, of around 42 months.

As regards label content, some obligations are already in force or imminent and are not affected by Simplification:

Classification according to the new CLP hazard classes, already in force.

Data carrier for the digital label, for those who choose to adopt it, already in force.

Indication of the European supplier, already in force.

From 1 January 2027, the “Contains” section of mixtures will also have to include substances classified in the new hazard classes.

We recommend that chemical companies that have not yet done so align now with these content requirements, regardless of the label format adopted: these are requirements that the Simplification Regulation does not change and whose deadlines are not moving back. Once Simplification enters into force, the supplier’s digital contact details will also have to be included on the label.

The role of digitalisation and EPY support for regulatory compliance in the chemical sector

EPY Srl develops regulatory-compliance software for chemical companies: safety data sheets, labels, transport documents and related obligations for the European market and for countries that have adopted regulations implementing the GHS.

Thanks to EPY X, companies can use a single classification database that feeds both SDSs and labels, integrates with their IT infrastructure and ensures document consistency, regulatory compliance and operational optimisation throughout the lifecycle of the chemical formulation.

For more than 40 years, EPY has been a trusted partner for chemical compliance thanks to the in-depth regulatory knowledge provided by its in-house Regulatory Team, which monitors and studies legislative developments and translates them into configurations, updates and practical operational guidance for customers.

At EPY, we put legislation (and a clear understanding of it) at the heart of what we do: through EPY Academy we offer a course dedicated to CLP and a programme of update webinars designed for those working in the chemical industry and in the paints, coatings, adhesives, sealants and inks sectors.

We will explore the subject of CLP labels in a presentation entitled “Future-proof CLP labels: practical strategies for ensuring long-term CLP compliance”, given by our Dr Patrizia Franchini on 29 October 2026 from 11:30 to 12:00 at Paint & Coatings Italy 2026.

We look forward to welcoming you at stand 232 at Paint & Coatings Italy 2026 to discuss CLP labelling, regulatory compliance and digitalisation of regulatory processes: register free of charge for the event and book a meeting with our team.

Paint & Coatings Italy 2026

Meet EPY at stand 232

28–29 October 2026 · Allianz MiCo, Milan

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