Europe Regulatory News

On 24 September 2025, the European Council approved the introduction of a “stop-the-clock” mechanism for the revised Classification, Labelling and Packaging (CLP) Regulation. The measure, part ...

On 24 September 2025, the European Council approved the introduction of a “stop-the-clock” mechanism for the revised Classification, Labelling and Packaging (CLP) Regulation. The measure, part of the Commission’s Omnibus VI simplification package, delays the entry into application of the new rules to 1 January 2028.

Purpose: Legal Certainty and Simplification

The mechanism is designed to provide legal certainty for businesses and to avoid a fragmented regulatory framework. Without the postponement, different provisions of the revised CLP would have applied on different dates, creating additional compliance challenges for companies.

The alignment of deadlines covers obligations on:

• Relabelling of substances and mixtures
• Formatting requirements for labels
• Advertisements and distance sales
• Labelling at fuel pumps

By postponing these obligations, the European Council aims to give companies, particularly SMEs, more time to adapt to the new requirements while ensuring continued protection of health and the environment.

Background: Original Deadlines

The revised CLP Regulation entered into force on 10 December 2024, with the majority of obligations initially scheduled to apply from 1 July 2026, and some provisions from 2027 (see more details here). The “stop-the-clock” mechanism shifts all these dates to 1 January 2028, creating a single, harmonised starting point for compliance.

Next Steps in the Legislative Process

Following the European Council’s approval, negotiations will continue with the European Parliament to finalise the regulation. The measure forms part of the broader Omnibus VI package, which seeks to simplify EU chemicals legislation while maintaining high levels of health and environmental protection.

On Tuesday, the EU Parliament finalized legislation aimed at reducing food and textile waste across the Union. The law sets binding targets to cut food waste by 10% in processing and 30% per capita...

On Tuesday, the EU Parliament finalized legislation aimed at reducing food and textile waste across the Union. The law sets binding targets to cut food waste by 10% in processing and 30% per capita in retail, restaurants, and households by 2030, while promoting the donation of safe unsold food. For textiles, producers will now bear the costs of collection, sorting, and recycling through new extended producer responsibility (EPR) schemes covering clothing, footwear, linens, and more, including e-commerce sellers. Member states are encouraged to address fast and ultra-fast fashion practices. The law will be signed and published in the EU Official Journal, giving countries 20 months to transpose it into national legislation.

Textile Waste and Hold Producers Accountable by 2030

The European Union has formally adopted new legislation aimed at reducing food and textile waste across member states by 2030. Under the updated rules, binding targets have been set to cut food waste by 10% in processing and manufacturing, and by 30% per capita in retail, restaurants, food services, and households. These reductions will be measured against the annual average of waste generated between 2021 and 2023. In addition, EU countries are required to ensure that key economic operators play an active role in preventing food waste and facilitating the donation of unsold food that is safe for human consumption.

The legislation also introduces extended producer responsibility (EPR) schemes for textile products. Producers making textiles available in the EU, including e-commerce sellers and companies based outside the Union, will be responsible for covering the costs of collecting, sorting, and recycling waste textiles. Member states are tasked with setting up EPR schemes within 30 months of the directive’s entry into force, with micro-enterprises allowed an extra year to comply. The rules cover clothing, footwear, accessories, blankets, bed and kitchen linen, curtains, and potentially mattresses. Governments are also encouraged to address fast and ultra-fast fashion practices when determining financial contributions to the EPR schemes. Following prior agreement by the Council, the European Parliament confirmed adoption of the act.

Further steps

The legislation is set to be signed by both co-legislators before being published in the EU Official Journal. Once in force, member states will have 20 months to implement the rules into their national laws.

On 15 September 2025, the European Chemicals Agency (ECHA) confirmed that its Socio-Economic Analysis Committee (SEAC) is expected to agree on a draft opinion regarding the EU-wide restriction of pe...

On 15 September 2025, the European Chemicals Agency (ECHA) confirmed that its Socio-Economic Analysis Committee (SEAC) is expected to agree on a draft opinion regarding the EU-wide restriction of per- and polyfluoroalkyl substances (PFAS) in March 2026. A 60-day public consultation will then open in spring 2026, focusing on socio-economic considerations.

September 2025 Committee Discussions on PFAS

At their September 2025 meetings, ECHA’s Risk Assessment Committee (RAC) and SEAC advanced work on the PFAS restriction proposal. Key topics under discussion included:

• Concentration limits and thresholds: determining levels above which PFAS would be restricted.
• Manufacturing and emissions control: assessing how PFAS are produced and how releases could be managed across sectors.
• Horizontal measures: examining approaches that apply broadly across industries instead of detailed sector-by-sector rules.

The committees noted that these issues will continue to be addressed in upcoming meetings to prepare the ground for their final opinions.

Plans for Upcoming Meetings

The committees also outlined their PFAS-related agenda for the coming months:

• December 2025:
• Electronics and semiconductors (SEAC)
• PFAS manufacturing (RAC and SEAC)
• Horizontal issues (RAC and SEAC)
• March 2026:
• Final discussion and adoption of RAC’s opinion
• Discussion and agreement on SEAC’s draft opinion, to be released for consultation

Next Steps in the Restriction Process

• Spring 2026: Launch of the 60-day consultation on SEAC’s draft opinion.
• End of 2026: Both RAC and SEAC aim to finalise their opinions, which will form the basis for the European Commission’s decision on the proposed PFAS restriction under REACH.

The upcoming consultation will follow a structured format, providing stakeholders from industry, NGOs, and the public with an opportunity to contribute evidence and views on the socio-economic impacts of the proposed PFAS restriction.

On 16 September 2025, the European Chemicals Agency (ECHA) announced the expansion of its ECHA CHEM database to include regulatory data on chemicals. The upgrade means that, in addition to substanc...

On 16 September 2025, the European Chemicals Agency (ECHA) announced the expansion of its ECHA CHEM database to include regulatory data on chemicals. The upgrade means that, in addition to substance information, users can now access details on regulatory processes and legal obligations under several EU laws.

Integration of Key EU Regulations

In this release, ECHA CHEM incorporates regulatory processes and lists from the following chemicals regulations and directives:

• REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)
• CLP (Classification, Labelling and Packaging) Regulation
• POP (Persistent Organic Pollutants) Regulation
• Drinking Water Directive

Under REACH, the update covers the list of restricted substances and the restriction process, the Authorisation List and ECHA’s recommendations for inclusion, substances of very high concern (SVHC) and the Candidate List, as well as dossier and substance evaluation.

This integration provides a single point of access to chemical identity data, classification and labelling information, REACH registration details, and other regulatory lists.

Drinking Water Directive Positive Lists

On 24 September 2025, ECHA further announced that the European positive lists under the Drinking Water Directive are now available in ECHA CHEM. The information is searchable, can be filtered by material type, and is linked with relevant data collected under REACH and CLP.

Improved Access and Transparency

The expanded system aims to improve transparency and efficiency by centralising regulatory and substance data. Companies, regulators, and other stakeholders can now more easily assess compliance obligations, restrictions, and potential risks related to chemical use.

Webinar Recording Available

ECHA presented the new features in a webinar on 23 September 2025. The session is now available for viewing and includes demonstrations of the platform and explanations of the first set of regulatory process and obligation lists. The recording can be accessed here.

The European Chemicals Agency (ECHA) announced on 9 September 2025 that it is continuing to verify the company size of registrants who declared themselves as micro, small, or medium-sized enterpris...

The European Chemicals Agency (ECHA) announced on 9 September 2025 that it is continuing to verify the company size of registrants who declared themselves as micro, small, or medium-sized enterprises (SMEs) at the time of their REACH registrations.

Correct declarations to avoid charges

Companies are advised to review their declared company size in REACH-IT. If the declared size is smaller than the actual company size at the time of submission, registrants should proactively inform ECHA’s Helpdesk. Early correction avoids the administrative charge, leaving only the requirement to pay the difference to the correct registration fee.

If ECHA discovers an incorrect size declaration during the verification process, companies will be required to pay both the difference in fees and an administrative charge of up to EUR 19,900.

Supporting documents required

Registrants must upload documents supporting their SME status in REACH-IT and regularly check their accounts for new messages and tasks. ECHA also reminds companies to keep their registrations and contact details up to date. Guidance on how to determine company size is available on ECHA’s website here.

ECHA has removed the harmonised classification of titanium dioxide (TiO₂, CAS 13463-67-7) from the C&L Inventory and updated the registry of intentions, following the Court of Justice of the Euro...

ECHA has removed the harmonised classification of titanium dioxide (TiO₂, CAS 13463-67-7) from the C&L Inventory and updated the registry of intentions, following the Court of Justice of the European Union (CJEU) ruling of 1 August 2025 annulling the classification. Related guidance documents on classification and labelling have also been deleted from ECHA’s website.

Annex VI to CLP Amended

The Court’s judgment directly amends Annex VI to the Classification, Labelling and Packaging (CLP) Regulation. The following entries no longer apply to titanium dioxide:

• Carc. 2 (H351: inhalation) classification
• Supplemental hazard statements EUH211 and EUH212
• Notes V, W, and 10

Immediate Effect for Businesses

Because the ruling has direct legal effect, the removal of the titanium dioxide entry does not require a further amendment (ATP) to CLP. Companies can already update safety data sheets (SDS) and labels to reflect the deletion of the harmonised classification.

Implications for Industry

The removal has significant implications for manufacturers and importers of paints, coatings, plastics, and other products containing TiO₂. Labelling requirements are now simplified, and suppliers can base hazard communication on their own product assessments rather than the harmonised entry.

The full text of the ruling of the European Court of Justice on the classification of titanium dioxide can be found here.

From 1 July 2026, the European Chemicals Agency (ECHA) will begin publishing the names of companies that have submitted classification and labelling (C&L) notifications under the CLP Regulation. Th...

From 1 July 2026, the European Chemicals Agency (ECHA) will begin publishing the names of companies that have submitted classification and labelling (C&L) notifications under the CLP Regulation. The name of every notifier will be made publicly available in the C&L Inventory in accordance with the amended Article 42 of the CLP, introduced by Regulation (EU) 2024/2865 published in the EU Official Journal on 20 November 2024.

Confidentiality Requests Before June 2026

Companies wishing to keep their name confidential must update their dossiers and submit a justification by 30 June 2026. Unless confidentiality is granted, ECHA will make notifier names publicly accessible from 1 July 2026. ECHA also released an updated CLP notification manual in June 2025 to guide companies through the process.

CLP Notification Requirements

Manufacturers and importers placing hazardous substances on the EU market are required to notify ECHA within a month of placing the substance on the market. Article 40 (1) of the CLP (Classification, Labelling and Packaging) Regulation outlines the data that must be included in the Substance dataset. The following details are needed for CLP notification (relevant IUCLID section in brackets):

·       Notifier details: Name and contact information (from REACH-IT).

·       Confidentiality request (notifier name): Justification and category must be provided.

·       Notifier contact person: To be specified in section 1.1.

·       Substance identity: According to Annex VI sections 2.1–2.3.4 (sections 1.1, 1.2, 1.4).

·       Confidentiality request (IUPAC name): Provide a publishable name for the C&L inventory and justification.

·       Classification: As required under the CLP Regulation (section 2.1).

·       No classification justification: Required if the substance is not classified under all hazard classes.

·       Reason for classification: Based on supporting data.

·       Concentration limits, M-factors, acute toxicity estimates: Where applicable, with justification referencing Annex I (section 13).

·       Label elements: Hazard pictograms, signal words, hazard statements.