On 17 August 2026, the European Commission formally notified the World Trade Organization (WTO) Technical Barriers to Trade (TBT) Committee of the draft revision to the Regulation on the classification, labelling and packaging of substances and mixtures (CLP Regulation, (EC) No 1272/2008) (notification number: G/TBT/N/EU/1234). The draft proposes to incorporate the latest scientific achievements of the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Revisions 8 to 11 into the EU legal framework, involving comprehensive adjustments to physical hazards, health hazard assessments, and hazard communication elements. CIRS provides the following interpretation of the draft.
I. Key Updates to Physical Hazard Classes
1. New hazard class: "Chemicals under pressure"
- Definition: Liquids or solids (containing ≥50% liquid/solid) contained in a pressure receptacle and pressurised to ≥200 kPa, excluding aerosols.
- Classification: Categories 1, 2 and 3 based on flammable component content and heat of combustion.
- Labelling: New hazard statements H282 (extremely flammable chemical under pressure), H283 (flammable chemical under pressure), and H284 (chemical under pressure).
2. Clarification of Aerosol classification criteria
The aerosol classification criteria (Section 2.3.1) in Revision 10, which had caused implementation difficulties, have been revised to clarify the applicability of ignition distance testing, enclosed space ignition testing, and foam flammability testing.
3. Explosives classification adjustments
- A new sub-category 2C is introduced (using the exclamation mark pictogram GHS07 instead of the exploding bomb pictogram).
- New hazard statements H209 (explosive), H210 (extremely sensitive), and H211 (may be sensitive) are added.
- Old hazard statements H200–H203 and H205 are deleted.
4. Others
- Fine-tuning of classification criteria for desensitised explosives.
- Revision of flammable solid criteria for metal powders.
II. Major Revisions to Health Hazard Classes
The most notable feature of this revision is the introduction of tiered assessment approaches, giving priority to non-animal data:
1. Skin corrosion/irritation (Section 3.2)
A six-tier assessment system is established: human/standard animal data (Tier 1) → in vitro/ex vivo data (Tier 2) → other animal data (Tier 3) → extreme pH (Tier 4) → non-testing methods (Tier 5) → overall weight of evidence (Tier 6).
2. Serious eye damage/eye irritation (Section 3.3)
A seven-tier assessment system is likewise introduced, with "Defined Approaches" added as an independent tier, allowing conclusions to be drawn from combinations of in vitro tests.
3. Skin sensitisation (Section 3.4)
- Completion of the revision of classification criteria for skin sensitisers from substances to mixtures, clarifying the criteria for Category 1A (strong sensitisers) and 1B (other sensitisers).
- Introduction of tiered assessment based on in chemico/in vitro methods and Defined Approaches.
4. Acute toxicity (Section 3.1)
It is stipulated that inhalation toxicity ATE values shall be based on 4-hour experimental exposure, and formulae for converting data from other exposure durations to 4 hours are provided (ten Berge equation and Haber's rule).
III. Comprehensive Adjustment of Labels and Precautionary Statements
The annexes have undergone large-scale "rationalisation" revisions to precautionary statements to improve readability and practicality:
- New codes: e.g. P203 (obtain and read all safety instructions before use), P236 (keep in original packaging), P265 (do not touch eyes), P316 (get emergency medical help immediately), P317 (get medical help), P318 (if exposed or concerned, get medical advice), P319 (if you feel unwell, get medical help), P354 (immediately rinse with water for several minutes), etc.
- Deleted codes: P201 and P202 (replaced by P203), and P310–P315 (replaced by P316–P319).
- Combined statement updates: e.g. P301+P310 changed to P301+P316; P305+P351+P338 supplemented by the alternative combination P305+P354+P338 (for skin corrosion/serious eye damage), etc.
- New combined hazard statements: e.g. H315+H319 (causes skin irritation and serious eye irritation).
ChemRadar Insights
Under WTO procedures, other Members may submit comments within 60 days of notification (before 16 October 2026). The regulation will become mandatory 24 months after publication in the Official Journal of the European Union. To reduce the burden on enterprises, substances and mixtures already classified and placed on the market under the old rules before the mandatory application date may continue to be sold for 48 months without immediate relabelling. Suppliers may also voluntarily apply the new rules before the mandatory date. Although the 48-month transition period provides a buffer, export enterprises are advised to assess their product portfolios as early as possible and initiate adaptive adjustments to labels and SDSs, given the lead time required for label redesign.
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