The CLP Revision and the Chemicals Omnibus: where are we at the end of 2026?

10 Dec 2025

Regular readers of our newsletter have no doubt been following along with the saga over labelling and other changes introduced by the CLP Revision in 2024, and the subsequent proposals to “roll-back” on some of these provisions published in the 6th Simplification Omnibus over the Summer.

Background

The CLP Revision, which was published as Regulation 2024/2865 back in October 2024, introduced many significant changes to the provisions of the CLP regulation to update it to legal and technical changes that have happened since its introduction back in 2008. A list of changes and their implementation dates can be found on the ECHA website.

Whilst some of the changes are relatively minor, others are set to have a profound impact on the chemical industry. These include requirements to update labels within six months for significant classification changes, new requirements for minimum font sizes, line spacing, font type and colour on labels, and stricter requirements to provide labelling information in adverts and for distance sales.

A “reality check” workshop held by the European Commission earlier this year highlighted some of the practical difficulties that industry faced in trying to implement the new requirements. As a result of this and other initiatives, the Commission heeded calls from industry for simplification of the complex regulatory requirements introduced by the CLP Revision to reduce compliance costs and strengthen global competitiveness. The 6th Omnibus published in July sets out plans to streamline and simplify key EU chemicals regulations, including two proposals to “roll-back” on some of the new CLP requirements.

What’s happened since?

Proposal one, known as the “Stop the Clock” proposal delays the introduction of some of these more difficult requirements until 1 January 2028 to allow time for them to be renegotiated. The proposal was pushed through the European Parliament using the urgent procedure to give industry some regulatory certainty and was published as Regulation (EU) 2025/2439 on 3rd December 2025.

What’s next?

Proposal two, which contains the proposed “roll-back” amendments, is expected to have a more complex path before adoption. The Council adopted its negotiating position on the proposals in early November, and this already includes several changes to the original proposal by the Commission. The Parliament has yet to agree its negotiating position, but this is also likely to include changes to the original proposal. The two bodies will then negotiate to produce a final text. These negotiations are expected to start in March or April 2026 and the process is expected to be significantly longer and more complex than the adoption of Proposal one. There are likely to be a number of changes to the original proposal text once agreement is reached.

How to prepare for what’s next

The “roll-back” will not mean returning to the pre-CLP Revision landscape—nor even to the Commission’s original proposal. However, industry hopes negotiations will ease some of the compliance burden. Thanks to the “Stop the Clock” proposal, businesses now have more time to adapt—but that window is limited.

Now is the perfect time to review your portfolio and plan the next steps in your compliance journey.

To understand the full implications for your product portfolio and develop a proactive strategy, get in touch with our expert consultants today. We’ll help you plan your next steps with confidence.

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