REF 14 starts in 2026 — will your SDS, PCN and labels hold up under inspection?

22 Jan 2026

If you place chemical mixtures on the EU market, 2026 is shaping up to be a critical year for compliance. Classification and labelling are the foundation of chemical safety, and right now, Europe has a compliance problem.

According to the Forum Work Programme 2026–2027, nearly half of all mixtures on the EU market fail to meet basic CLP duties. The Forum’s project on classification and labelling found that:

44% of mixtures are non compliant with CLP requirements
17% are incorrectly classified
33% are incorrectly labelled
And in a related pilot project, 29% of products requiring child resistant fastenings did not comply

These figures reveal a systemic issue: essential hazard information is too often incomplete, inaccurate, or missing altogether, leaving both consumers and workers at risk. With multiple revised CLP obligations becoming applicable in 2026, the Forum has made it clear that enforcement must tighten.

That is why REF 14 has been prioritised as a major coordinated enforcement action for 2026. Its purpose is straightforward but critical: to harmonise enforcement of core CLP duties and significantly raise compliance across the EU market.

What will REF 14 inspectors be looking for?

Currently, inspection manuals are under development, with EU wide on site checks scheduled for the first half of 2026. These inspections will focus heavily on whether companies have met their obligations under the CLP Regulation, and whether that compliance is consistent across all required documentation.

REF 14 inspectors will be examining:

Classification and labelling
Packaging, including the presence and correctness of child resistant fastenings
Safety Data Sheet (SDS) content, format and alignment with the latest classification
Poison Centre Notifications (PCNs), including UFI accuracy and update status

Any mismatch, whether between the SDS and the label, the label and the PCN, or the PCN and the classification, is exactly the kind of inconsistency REF 14 is designed to identify.

What are the risks of non-compliance?

Under Article 47 of CLP, each Member State sets its own penalties for non compliance, and they must be effective, proportionate and dissuasive. This means businesses can face anything from administrative fines to product withdrawals, depending on the country.

Beyond financial penalties, non compliance can disrupt supply chains, stall market access and damage brand integrity, especially where inconsistencies are found between the SDS, label or PCN. REF 14 will place a strong focus on these alignment issues, increasing the likelihood that non compliance will be detected.

How to get your compliance back in alignment

Solving these issues now is far more efficient than responding under enforcement pressure and REF 14 only reinforces that SDS, PCN, UFI and label alignment is not a one off task but an ongoing responsibility.

Many companies still struggle with maintaining their PCNs, SDS and labels especially when routine business changes, formulation tweaks, supplier substitutions, Mixture in Mixture (MiM) changes or new Adaptation to Technical Progress (ATP) classifications silently trigger the need for updates.

This is exactly what the chemical experts at Ricardo support its partners with:

Ensuring SDS contain classifications are accurate, current and reflect regulatory changes
Fully aligning labels with the latest classification and market/language requirements
Maintaining consistent PCN submissions and UFI assignments across all EU markets, including recognising when updates or new UFIs are triggered
Updating SDS content to reflect formulation changes, new hazard data or revised CLP obligations
Checking portfolio wide consistency ahead of REF 14 inspections, so that your SDS, label and PCN tell the same story.

If you have any questions or concerns about your business and the potential risks of REF-14 inspections, contact our experts today.

Chemical regulatory and compliance

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