EU Proposes Updates to CLP Regulation, Involving 48 Chemicals

On November 27, 2025, the European Commission issued notification G/TBT/N/EU/1172 to the World Trade Organization (WTO) Technical Barriers to Trade Committee, announcing a planned technical update to the Classification, Labelling and Packaging Regulation (CLP, EC 1272/2008). The update involves addition of 38 new entries and revision to 10 existing entries in Annex VI.

Key Revisions

1. Addition/Update of Substance List

Annex VI, Table 3 of the CLP Regulation is amended to include the harmonised classification of the following substances (examples include):

• Borates: Including potassium metaborate, sodium octaborate, and magnesium metaborate, all classified as Reproductive Toxicity Category 1B.
• Phosphonates: Such as sodium and potassium salts of ethylenediaminetetramethylphosphonic acid, classified as Carcinogenicity Category 1B.
• Phenols and Ketones: Such as Bisphenol F, 4-phenylbenzophenone, involving classifications including Reproductive Toxicity Category 1B, skin sensitisation, and chronic aquatic toxicity.
• Acids and Esters: Such as propylene glycol monomethacrylate, perfluorohexanoic acid, involving classifications including Reproductive Toxicity Category 1B and Specific Target Organ Toxicity – Repeated Exposure Category 2.

2. New Note 13 

Requires that the hazards of mixtures containing a common molecular entity (bromide ion) be calculated based on the summation of concentrations. If the total concentration of certain bromide salts in a mixture reaches a specific threshold, the mixture must be classified as Reproductive Toxicity Category 1.

Full details of the revisions can be found via the link below.

https://members.wto.org/crnattachments/2025/TBT/EEC/25_08180_01_e.pdf

The regulation is expected to be adopted in the first quarter of 2026. It will enter into force 20 days after its publication in the Official Journal of the European Union, with an 18-month transition period granted to industry.

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