Regulation (EU) 2024/2865 brings changes to labelling, online sales and advertising of chemical products

📅 Date of publication: 20 November 2024📄 Regulation amended: CLP Regulation (EC) No 1272/2008🔍 What’s changing? New requirements apply to labels, online offers, advertising and classification of so-called MOCS.

New CLP Labelling Requirements

The European Commission aims to improve user safety and label readability. The changes introduce:

• Minimum font sizes (e.g. 1.2 mm x-height for packages ≤ 0.5 L),

• Specific label and pictogram dimensions,

• Black text on a white background,

• Use of a clear, sans-serif font with proper line spacing and letter spacing.

📦 What does this mean in practice?

Many companies will need to redesign their labels to ensure compliance with both legal and branding requirements.

Deadlines for Updating CLP Labels

The vague requirement to act “without undue delay” has been replaced with clear deadlines:

• 6 months – for changes involving new or stricter hazard classification, or new supplemental information,

• 18 months – for all other changes (e.g. classification downgrade).

🕒 What does this mean in practice?

Internal procedures must ensure timely updates once new classification data is available.

Advertising and Online Sales

Under the new rules, full CLP labelling must be presented in:

• Advertising of hazardous substances or mixtures,

• Online listings where consumers can purchase without seeing the label.

This includes hazard classes/categories, pictograms, H-, P- and EUH-statements, signal words, and the mandatory phrase:

“In all cases, follow the instructions on the product label.”

💻 What does this mean in practice?

Online shops and marketing teams must review and revise product descriptions and visuals.

Green Claims Prohibited

The regulation explicitly prohibits misleading green claims like:

“non-toxic”, “harmless”, “environmentally friendly” for products classified as hazardous.

🌱 What does this mean in practice?

Marketing content and packaging claims must align with actual hazard classification.

MOCS – Multi-Constituent Substances

The new regulation introduces and defines MOCS (Multi-Constituent Substances):

• Classified as mixtures, based on known data for each constituent,

• Exception: botanical extracts not chemically modified (as per REACH Art. 3(40)) may be treated differently based on scientific evidence.

🧪 What does this mean in practice?

Companies must reassess MOCS classifications, especially for substances with hazardous constituents.

Other Changes

• Digital labels – allowed but do not replace physical labels,

• Refill station sales – new provisions apply,

• Rules on fold-out labels and child-resistant packaging have been expanded.

📌 What does this mean in practice?

A holistic review of your product labelling and distribution practices is recommended.

Need support?

We help you assess how the CLP update affects your business, products, and compliance documentation.

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