November 1, 2026, is a date you cannot afford to miss if you supply substances marketed before May 1, 2025.
That day marks the end of the last transitional period granted for substances by Delegated Regulation (EU) 2023/707. From November 1, 2026, substances placed on the EU market before May 1, 2025 and still present in the supply chain must also be classified and labelled in accordance with the new criteria, where applicable. No further extension is envisaged, and there is no phase-out period for stock already present in the supply chain.
And no, “Stop the Clock” does not move this deadline. Regulation (EU) 2025/2439 and Omnibus VI concern obligations introduced by the revision of CLP, Regulation (EU) 2024/2865: neither of them affects the transitional periods of 2023/707.
Who is affected by the deadline?
To apply the transitional period correctly, you need to look at when the individual quantities of a substance were placed on the EU market.
New quantities of a substance already on the market, placed on the market as of May 1, 2025, must already meet the new classification and labelling criteria.
The transitional period until November 1 ,2026, covers instead the quantities of the substance placed on the market before May 1, 2025 and already present in the supply chain.
The benefit of the transitional period is also conditional on there being no change in formulation. Where the formulation of the substance changes, all the quantities placed on the market must be classified and labelled in accordance with the new May 2025 criteria.
The operational checklist from now to 1 November
- Map your portfolio: identify the substances you place on the EU market that were first placed on the market before 1 May 2025 and have not yet been re-assessed. Do not forget substances supplied in small volumes, intermediates handled under conditions that are not strictly controlled, and the substances you import.
- Carry out the assessment : normally the assessment does not require new experimental data to be generated for the sole purpose of CLP classification. The analysis must start from all the available and relevant information, applying the principles of weight of evidence and expert judgement. The criteria for the new classes expressly provide for the use of different sources: in vivo and in vitro experimental data, read-across, QSAR models and in silico predictions, monitoring and field data, and the scientific literature. A good starting point is the lists published by ECHA: the substances discussed by the ED Expert Group and by the PBT Expert Group, and the harmonised entries in Annex VI.
- Use the final guidance: the Guidance on the Application of the CLP Criteria was reissued on 13 November 2024 in five separate documents and now covers the new classes in full: endocrine disruption for human health (3.11) and for the environment (4.2), PBT/vPvB and PMT/vPvM (4.3 and 4.4). The earlier draft version has been replaced by the version published in November 2024.
- Update your REACH registration dossiers: the new hazard classes have been available in IUCLID since April 2024. The deadlines are not the same for every type of update: for a change in classification and labelling, Implementing Regulation (EU) 2020/1435 sets six months from the event that makes the update necessary, while members of a joint submission have three months from the confirmation that the update submitted by the lead registrant is complete. In practice the bottleneck sits upstream, because agreeing the classification within the joint submission depends on other people’s timelines: it is worth opening that discussion well in advance.
- Update the C&L notification to the Inventory: bear in mind that since 1 July 2026 ECHA has published the name of the notifier on ECHA CHEM, under Article 42 as amended by Regulation (EU) 2024/2865, unless a duly justified confidentiality request is included in the dossier.
- Review labels and safety data sheets: the label should contain: new signal word, hazard statement and precautionary statements. In the SDS: new classification, hazard information and regulatory references. Pay attention to substances that were not classified at all before: it may now be necessary to draw up an SDS where there was previously no obligation to do so.
- Inform your downstream users: the classification of your substance feeds directly into the classification of your customers’ mixtures. A component classified as ED HH category 1 at a concentration of 0.1 % or above, or ED HH category 2 at 1 % or above, or PBT/vPvB/PMT/vPvM at 0.1 % (w/w) or above, triggers classification of the mixture, with knock-on effects on labels, poison centre notifications and, where an ED category 2 is present at 0.1 % or above, on the obligation to make an SDS available on request.
The new CLP update also consider the 2023 hazard classes
Regulation (EU) 2023/707 introduced new CLP hazard classes covering endocrine disruption (ED) for human health and the environment, as well as PBT/vPvB and PMT/vPvM properties. These categorizations depend upon interconnected evaluations: separate evaluations are done for both ED HH and ED ENV, whereas Category 1 endocrine disruptors satisfy the criterion of toxicity needed for PBT and PMT categories. The regulation also sets out new hazard communication provisions, although there are no pictograms allotted to these categories at present. Thus, labels need to make use of signal words and hazard/ precautionary statements.
How this affect mixtures?
For mixtures the picture is one step further ahead as mixtures placed on the market as of 1 May 2026 must already be compliant; those already on the market before that date have time until 1 May 2028. In concrete terms, the work you are doing now on substances is the raw material your formulation teams will need over the next eighteen months: an excellent reason to document the assessments properly rather than resolving them case by case.
What Chemsafe can do as your partner
Chemsafe supports companies along the whole chain of obligations triggered by the new hazard classes: screening of the substance portfolio, weight of evidence assessment against the criteria in sections 3.11, 4.2, 4.3 and 4.4 of Annex I, updating of REACH registration dossiers and C&L notifications, review of labels and safety data sheets, and management of the knock-on effects on mixtures and poison centre notifications.
If you still have substances to assess before 1 November, get in touch: there is time, but not a great deal of it.
Contact us now to assess your chemical compliance.
