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When do the new CLP label rules apply?

As of · sourced from primary law · not legal advice · Auf Deutsch lesen

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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

The new formatting rules of the CLP amendment, the rules on advertisements and distance sales offers and the new time limits for updating labels (Art. 30 CLP) apply only from 1 January 2028. This follows from the “stop the clock” Regulation (EU) 2025/2439, published on 3 December 2025. The amendment itself, Regulation (EU) 2024/2865, has been in force since 10 December 2024. Many pages still say 2026. That is out of date.

Regulations (EU) 2024/2865 and 2025/2439

The dates at a glance

These dates are settled:

  • 10 December 2024: the CLP amendment, Regulation (EU) 2024/2865, enters into force.
  • 3 December 2025: “stop the clock”, Regulation (EU) 2025/2439 of 26 November 2025, is published in the Official Journal.
  • 1 July 2026: the digital label and the fold-out label apply, among other things.
  • 1 January 2027: distributors submit information to the appointed bodies (poison centres) where they distribute mixtures in other Member States, or rebrand or relabel them. The obligation does not apply if they can demonstrate that the appointed body already received the same information from importers and downstream users (Art. 45(1c) CLP).
  • 1 January 2028: the formatting rules (Art. 31(3) and section 1.2.1 of Annex I to CLP), the new time limits for updating labels (Art. 30), advertisements (Art. 48) and distance sales offers (Art. 48a) apply. You may apply the formatting rules, the time limits for updates and the new advertisement rule voluntarily until 31 December 2027 (Art. 2(6) of Regulation (EU) 2024/2865).
  • 1 January 2029: until then, goods labelled under the previous formatting rules and placed on the market before 1 January 2027 are not required to be relabelled (Art. 61(8) CLP).

What changes

Among other things, the CLP amendment brings minimum font sizes, information in distance sales offers and a voluntary digital label. The “stop the clock” Regulation amends only Art. 2 of Regulation (EU) 2024/2865: formatting, the time limits for updating labels, advertisements and distance sales offers apply from 1 January 2028 instead of earlier.

The transitional rules for goods on the market are in Art. 61 CLP, which the “stop the clock” Regulation did not amend. Substances and mixtures classified, labelled and packaged under the previous rules and placed on the market before 1 July 2026 are not required to be classified, labelled and packaged in accordance with the amended Regulation until 1 July 2028 (paragraph 7). Those labelled under the previous formatting rules and placed on the market before 1 January 2027 are not required to be until 1 January 2029 (paragraph 8).

Where sources name an earlier start, they mostly rest on the position before the postponement.

What the digital label is

The digital label is voluntary. It supplements the physical label with access to information, for example through a QR code. What must be on the label itself and what may be provided digitally only is set out in the text of the CLP amendment. Check it there before you change labels.

The omnibus may still move the dates

Parliament approved Omnibus VI on 22 October 2026 (T10-0362/2026). The Council and publication in the Official Journal are outstanding. The text sets no fixed year 2030 but 18 months from entry into force for formatting, advertisements and distance sales offers, and 36 months for further parts. Until publication, 1 January 2028 remains the law. Plan with it and check the position before you print.

What to do now

You have time, but not without limit.

  • List all labels you are responsible for.
  • Check which font sizes and formats apply so far.
  • Plan the changeover before 1 January 2028, not for the date itself.
  • Decide whether you want to use a digital label.
  • Check the information in online offers.

Frequently asked questions

Does anything new apply to labels in 2026?

Yes. Since 1 July 2026 the rules on the digital label and the fold-out label apply, among other things. Formatting, the time limits for updating labels, advertisements and distance sales offers begin only on 1 January 2028 (“stop the clock”, Regulation (EU) 2025/2439). From 1 January 2027 the submission duty for distributors under Art. 45(1c) CLP applies, unless they can demonstrate that the appointed body already received the same information.

Is the digital label mandatory?

No, it is voluntary.

What about the UFI?

The transitional period for the UFI ended on 1 January 2025. It is on the label after “UFI:” and has 16 characters.

With ProofPass

In the Safety data sheets module every product has its own page with safety data sheet and UFI. A QR code leads there. That is not a digital label under Art. 34b CLP, because the page does not separate the label elements from other information.

The terms and legal notices are in German, and the German version is binding.

Sources

As of 10 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.