2024 CLP Revision and Stop the Clock: Impact on Labelling and Compliance
The CLP Regulation (EC 1272/2008) dictates how chemical substances and mixtures are classified, labelled, and packaged within the EU. This ensures hazards are communicated uniformly, enhancing safety for both human health and the environment.
The 2024 CLP revision introduces structural changes regarding legibility, multi-layer labelling and digital information provision. Furthermore, the recent “Stop the Clock” regulation shifts several implementation deadlines to 1 January 2028. In this publication, we analyse the impact on labelling based on our own research and a comparison of the relevant articles and annexes.
This presentation is the result of independent research into CLP and "Stop the Clock" procedures; the content is for informational purposes only and does not constitute legal advice.
Under the Microscope
In this presentation, we examine four major pillars that make the difference in audits and day-to-day practice:
- Legibility: Not just "aesthetic", but legally enforceable.
- Fold-out labels (multilayer): From an exception to a structural solution.
- Digital labels: Additional information is permitted, but within strict boundaries.
- New timing due to "Stop the Clock": Deadlines are shifting, but preparation remains crucial.
The CLP rules clarify that a label must:
- be durably attached to the immediate packaging
- be horizontally legible when the package is in its normal position
In addition, the formatting requirements have become much more specific:
- Text: black on a white background
- Line spacing: a minimum of 120% relative to the font size (e.g., 10 pt → 12 pt)
- Typography: a single sans-serif font and sufficient letter spacing
Under CLP 2008, fold-out labels were primarily seen as a last resort when the shape or size of the packaging made standard labelling impossible. The CLP revision now offers more flexibility: fold-out labels are explicitly permitted, provided they adhere to specific formatting and content rules.
The new logic: front page / inside pages / back page The revision distinguishes between:
- Front page (front)
- Inside pages (grouped by language)
- Back page (base layer)
The front page must contain, at a minimum: supplier details, product identifiers, hazard pictograms, signal words (in all languages used inside), the UFI, and a reference/symbol indicating that the label can be opened.
The inside pages contain all required labelling elements (with some exceptions), clearly grouped per language.
The back page must continue to display the core information, even if the upper layers are removed or detached.
The presentation clarifies:
- Digital labels (QR/app) are intended as a supplement.
- Article 17 (core labelling requirements) must remain physically on the product.
The digital carrier must be correctly applied. If information is only provided digitally, it must be accompanied by a clear notice (e.g., “More hazard information can be found online” or similar).
Technical requirements that are often underestimated
The digital label must, among other things:
- be searchable
- be free of charge (no registration or mandatory app installation)
- require a maximum of 2 clicks to access information
- remain available for at least 10 years
- be compatible with common operating systems and browsers
Prohibit tracking, except for what is strictly necessary
“Stop the Clock” was published on 3 December and will formally enter into force on 23 December 2025.
Key point: Deadlines from the CLP revision are being shifted to 1 January 2028.
In addition, a phased timeline (2026–2029) is presented, focusing on:
- rules regarding fold-out labels
- identification of hazard-determining substances in mixtures
- horizontally legible UFI codes
and the final deadline by which "full compliance" is required (including the impact on relabelling)
Download the presentation: full overview + sources
In the presentation, you will also find:
- Legal references and links to relevant EU texts and ECHA guidance;
- Concrete requirements per topic (legibility, multi-layer, digital);
- The deadline timeline as detailed in the research.
Disclaimer
This publication is based on independent research into CLP and “Stop the Clock” procedures and is for informational purposes only. This does not constitute legal advice.
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