CLP ATP Deadlines 2026: EU CLP ATP 22 Compliance Guides

The EU Classification, Labelling and Packaging (CLP) Regulation (Regulation (EC) No 1272/2008) is regularly updated through Adaptations to Technical Progress (ATPs). These updates introduce new or revised harmonised classifications for substances, directly affecting how products are classified, labelled, packaged, and documented in the EU.

Several CLP ATPs have mandatory application dates in 2026, making early preparation critical for companies placing substances or mixtures on the EU market — particularly non-EU manufacturers exporting into the EU.

Key CLP ATP Deadline in 2026

22nd ATP – Application Date: 1 May 2026

The 22nd ATP to CLP, updating Annex VI (harmonised classifications), will apply from 1 May 2026.

From this date:

• New and amended harmonised classifications must be applied

• Suppliers are responsible for updating labels and Safety Data Sheets (SDSs) for affected substances and mixtures

• Substances and mixtures placed on the market from 1 May 2026 must reflect updated classifications, labelling, and hazard information

• Companies may apply the updated classifications earlier on a voluntary basis

However, 1 May 2026 is the mandatory compliance deadline.

Other Ongoing CLP Developments

Draft and Upcoming ATPs

The EU has notified the WTO of a draft ATP proposing new and revised harmonised classifications for additional substances. Adoption is expected following consultation in early 2026.

23rd ATP – Future Planning

The 23rd ATP has been adopted and will apply from 1 February 2027. While not a 2026 deadline, companies should begin impact assessments now to avoid future compliance pressure.

Core Requirements Under the EU CLP Regulation

Companies placing substances or mixtures on the EU market must comply with the following obligations:

1. Classification

• Classify substances and mixtures according to current CLP criteria

• Apply mandatory harmonised classifications listed in Annex VI

2. Labelling

Labels must include:

• Correct hazard pictograms

• Appropriate signal word

• Hazard (H) and precautionary (P) statements

• Required EU language(s)

• Clear, durable, and compliant formatting

3. Packaging

• Prevent leakage

• Meet CLP safety design requirements

4. Safety Data Sheets (SDS)

• Update SDSs to reflect revised classifications and hazard data

• Provide SDSs in the official language(s) of each EU Member State where products are marketed

5. Classification & Labelling Notification

• Update or submit C&L notifications to the European Chemicals Agency (ECHA) when classifications change

• Communicate updates promptly throughout the supply chain

Who Is Impacted?

• EU manufacturers

• EU formulators

• EU importers

• Non-EU manufacturers exporting to the EU (via importers or Only Representatives)

For companies outside the EU, ensuring compliant SDSs and CLP-aligned labelling reflecting harmonised classifications by 1 May 2026 is essential to maintain uninterrupted EU market access.

Why Early Preparation Matters

Failure to meet the 1 May 2026 deadline can result in:

• Shipment delays or border holds

• Market withdrawals or enforcement action

• Increased regulatory exposure

• Higher compliance and relabelling costs

Proactive impact assessments allow companies to align classification, labelling, and SDS updates well ahead of the mandatory application date — reducing operational disruption and regulatory risk.