EU Proposes Simplification of CLP, Cosmetics and Fertiliser Rules; Key Labelling Requirements to Be Postponed to 2028

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.