CLP digital label and the 2028 date for new label rules
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.
The short answer
Regulation (EU) 2024/2865 amended the CLP Regulation: minimum font sizes, details in distance selling and a voluntary digital label, among other things. Regulation (EU) 2025/2439 moved the main format rules to 1 January 2028. The safety data sheet is not replaced by a digital label.
Regulations (EU) 2024/2865 and 2025/2439
What changes
The amendment has been in force since 10 December 2024. Among other things it brings:
- Minimum font sizes and line spacing for hazard labels
- Mandatory details also in online offers and distance selling
- A voluntary digital label in addition to the physical label, through a data carrier such as a QR code
- Rules for refill stations
The move to 2028
With the “stop the clock” Regulation (EU) 2025/2439 of 3 December 2025, the new format rules, the rules on advertising and distance selling and the transition periods for relabelling apply only from 1 January 2028.
Parliament approved Omnibus VI on 22 October 2026 (T10-0362/2026). The Council and the Official Journal are outstanding. The text sets no fixed year 2030 but 18 and 36 months from entry into force. Until publication, 1 January 2028 remains the law. Check the position before you print labels.
Digital label and safety data sheet
The digital label addresses users and supplements the physical label. The safety data sheet addresses professional recipients, and you supply it under REACH. A QR code replaces neither duty. If it leads to the digital label, the label elements sit together in one place, separate from other information (Art. 34b(1)(a) CLP).
Frequently asked questions
May I move details from the physical to the digital label?
Only in the cases the Regulation expressly permits. Hazard pictograms, signal word and the essential statements stay on the physical label.
How long must a digital label stay retrievable?
The availability requirements are in the text of Regulation (EU) 2024/2865. Check them there before you commit. A fixed address that is not tied to your website is the safest basis.
With ProofPass
A QR code per product in ProofPass leads to the product page with the current data sheets on a fixed address, independent of your website. That is not a digital label under Art. 34b CLP: the page does not separate the label elements from other information, and ProofPass counts scans anonymously. Art. 34b(2) limits analysis of use to what is strictly necessary.
The dashboard and the sign-up form are in German.
Sources
As of 3 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.