Amendment to CLP Regulation: What Chemical Manufacturers and Distributors Must Review

Key data

If your company manufactures, imports or distributes chemical substances or mixtures in the European Union, this corrigendum requires you to take action. The Regulation (EU) 2018/669 already adapted the CLP framework to technical and scientific progress; now, the correction published on 22 September 2026 amends errors in that text, which may alter hazard classifications, pictograms or H/P statements that you already have printed on your labels or documented in your safety data sheets (SDS).

The CLP Regulation (EC) 1272/2008 is the reference standard in the EU for the classification, labeling and packaging of hazardous substances and mixtures. Any correction to its derived texts has a direct effect on the technical and regulatory documentation of the affected products.

What does this regulation establish?

A corrigendum does not introduce new obligations from scratch: it corrects material or translation errors in an already published regulation. In this case, the corrected text is Regulation (EU) 2018/669, which modified the annexes of the CLP to reflect technical and scientific advances in the classification of hazardous substances.

The corrections may affect any of the following elements of the CLP Regulation:

• Hazard classifications: categories of hazard assigned to specific substances or mixtures (acute toxicity, environmental hazard, etc.).
• Hazard pictograms: the visual symbols that must appear on the label.
• Hazard statements (H): standardized indications about the nature of the risk.
• Precautionary statements (P): indications about preventive, response, storage and disposal measures.
• Packaging procedures: requirements on the type or closure of containers for certain substances.

Since the corrigendum corrects the text of Regulation (EU) 2018/669 published in Official Journal L 115 of 4 May 2018, companies that have already adapted their documentation to that regulation must verify whether the corrections now published invalidate any of the changes they applied at the time.

Economic and operational impact

The direct impact translates into costs for document review and updating. Depending on the number of affected products and the scope of the corrections, companies may face:

• Redesign and reprinting of labels for products whose classification, pictogram or H/P statements have changed.
• Update of safety data sheets (SDS), which must always reflect the current CLP classification.
• Review of packaging procedures if the corrections affect closure or container type requirements.
• Communication to the supply chain: distributors and industrial customers must receive updated SDS.

The greatest economic risk is not in the cost of updating, but in non-compliance. The CLP Regulation provides for administrative penalties and may result in marketing restrictions for products that do not comply with the correct classification and labeling. In Spain, the power to impose sanctions on chemical products is held by the autonomous communities, with amounts that can be significant depending on the severity of the infraction.

Who does it affect?

• Manufacturers of chemical substances and mixtures based or operating in the EU.
• Importers who introduce substances or mixtures into the European market from third countries.
• Distributors who market chemical products regulated under the CLP.
• Pharmaceutical sector to the extent that it handles substances classified under the CLP.
• Industrial cleaning and maintenance products sector containing classified hazardous substances.
• Occupational health and safety managers who manage safety data sheets in their organizations.
• Regulatory advisors and product consultants who manage the technical documentation of their clients.

Practical example

Imagine a distributor of industrial cleaning products that, following the publication of Regulation (EU) 2018/669 in May 2018, updated the labels and safety data sheets of its catalog of 40 references. Now, the corrigendum published on 22 September 2026 corrects some of the classifications or H/P statements that that regulation introduced.

The company's regulatory manager must:

1. Access the text of the corrigendum in the EU Official Journal and compare it with the 2018 version.
2. Identify which of its 40 references contain the substances or mixtures affected by the corrections.
3. If any reference is affected, update the SDS and redesign the label before continuing to market the product.
4. Notify its industrial customers of the shipment of the revised SDS, as required by the CLP Regulation itself.

Failing to act in time means marketing a product with incorrect labeling, which may result in an inspection and removal of the product from the market.

What should companies do now?

1. Access the text of the corrigendum in the EU Official Journal (OJ:L_202690791) and read the specific corrections to Regulation (EU) 2018/669.
2. Compare the corrections with current documentation for each product: labels, safety data sheets and packaging specifications.
3. Identify affected products whose classifications, pictograms or H/P statements are modified by the corrigendum.
4. Update the safety data sheets (SDS) of affected products, reflecting the corrected CLP classification.
5. Redesign and reprint the labels of affected products before continuing their marketing.
6. Communicate updated SDS to distributors and industrial customers in the supply chain, in accordance with CLP Regulation obligations.
7. Document the review process to be able to demonstrate to an inspector that the necessary measures have been taken in a timely manner.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690791