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On 8 July 2025, the European Commission published a wide-ranging legislative proposal package aimed at simplifying the EU’s chemicals legislation. This includes significant proposed amendments to the Classification, Labelling and Packaging (CLP) Regulation, the Cosmetics Regulation, and the Fertilising Products Regulation. The proposals also include a separate regulation that postpones key labelling obligations under the CLP Regulation until 1 January 2028.

Key Proposals: Greater Flexibility and Reduced Compliance Burden

The central legislative text (COM(2025) 531) proposes targeted amendments to three major regulations to address compliance challenges, reduce the administrative burden and enhance regulatory clarity across the chemicals sector. Accompanying the proposal is a detailed Annex outlining specific changes to the legal text, which is particularly relevant for compliance teams and legal counsel.

Highlights include:

• CLP Regulation (EC No 1272/2008):

  • Replaces rigid formatting rules (e.g. fixed font size and black-on-white labels) with readability standards, allowing for greater flexibility across product types.

  • Allows broader use of digital labelling to provide supplementary information online.

  • Revises Article 31 to simplify physical label requirements - label elements must be clear, indelible and contrasting with the background, but a fixed layout is no longer required.

• Cosmetics Regulation (EC No 1223/2009):

  • Removes the pre-notification requirement for nanomaterials.

  • Introduces clearer procedures for adding new UV filters, preservatives, and colourants to product annexes.

• Fertilising Products Regulation (EU 2019/1009):

  • Eliminates the need for extended REACH registration for certain component substances.

  • Simplifies the approval process for micro-organisms and introduces digital conformity documentation.

Postponement of CLP Amendments to 2028

In parallel, the Commission published a second legislative act (COM(2025) 526) which aims to postpone the implementation of certain controversial provisions introduced by Regulation (EU) 2024/2865. This includes changes to:

• Label layout and formatting

• Advertising rules

• Labelling for online and distance sales

The revised date for the entry into force of these provisions is now set for 1 January 2028, which gives industry more time to adapt.

Impact and Next Steps

According to the Commission’s impact assessment, the simplification measures are expected to save the chemicals sector up to €363 million annually without compromising health or environmental protection. These proposals form part of a broader effort under the EU’s Chemicals Industry Action Plan to promote competitiveness and innovation.

The simplification proposal (COM(2025) 531) and the postponement regulation (COM(2025) 526) will now proceed through the ordinary legislative procedure, involving review and potential amendment by the European Parliament and Council.

On 25 June 2025, the European Chemicals Agency (ECHA) formally requested that its Committee for Risk Assessment (RAC) reassess the hazard classification of glyphosate (CAS no 1071-83-6) under Article 77(3)(c) of the REACH Regulation. This decision follows the submission of new scientific evidence during the renewal process for glyphosate’s approval as an active ingredient in plant protection products.

Trigger for the Reassessment: New Genotoxicity Study

The request is primarily driven by the availability of a new in vivo genotoxicity study that was not previously assessed by the RAC in its 2022 evaluation. Conducted as part of the pesticide renewal process, the study has raised questions regarding the potential mutagenic effects of glyphosate.

Focus of the Reassessment

ECHA has asked RAC to:

• Re-examine glyphosate’s classification for carcinogenicity, mutagenicity, and reproductive toxicity (CMR) under CLP Regulation (EC) No 1272/2008.

• Review additional scientific evidence and new information provided during the pesticide renewal process.

• Address public concerns and ensure alignment with the latest EU regulatory decisions.

Current Classification Status

Glyphosate is currently classified in the EU as follows:

• Eye damage 1 (H318): Causes serious eye damage.

• Aquatic chronic 2 (H411): Toxic to aquatic life with long-lasting effects.

Despite ongoing public and scientific debate about its potential health effects, glyphosate is not classified for carcinogenicity, mutagenicity, or reproductive toxicity.

The European Commission’s Implementing Regulation (EU) 2024/197, which renewed glyphosate’s approval, highlighted this data gap. This prompted the Commission to invite ECHA to re-examine the classification in an independent process.

15-Month Deadline for RAC Opinion

ECHA has set a 15-month deadline for RAC to deliver its opinion, ensuring that the process moves forward in a timely and transparent manner.

The reassessment reflects ECHA’s ongoing commitment to ensuring that chemical hazard classifications are based on the latest scientific evidence, while protecting human health and the environment.