Adaptations to technical progress (ATPs) of the CLP Regulation regularly update the harmonized classifications of hazardous substances. For paint and coating manufacturers, these changes are not simply regulatory updates: they may require updating Safety Data Sheets (SDS), CLP labels, Unique Formula Identifiers (UFI) and, depending on the case, notifications to poison centers (PCN).

ATP23, applicable from February 1, 2027, represents a significant milestone for many companies. Regulatory changes do not stop there. A draft ATP24 has already been published by the European Commission, illustrating the continuous pace of CLP Regulation updates. For manufacturers, the challenge is therefore no longer to react to each new ATP, but to implement a method to anticipate these changes.

Why Each ATP Can Impact Your Products

Each ATP updates Annex VI of the CLP Regulation by introducing new harmonized classifications or modifying existing classifications. Manufacturers must therefore quickly identify the substances concerned in order to assess the impacts on their mixtures.

ATP23 provides a concrete example of this approach. It notably introduces 22 new harmonized classifications and 10 modifications to existing classifications, which may affect certain ingredients used in paints and coatings.

Among the substances concerned are certain isothiazolinones, used as preservatives in some formulations. A change in their classification can modify the applicable regulatory requirements, even when the product composition remains unchanged.

In practical terms, a formulation may require a regulatory update without any modification having been made to the product itself. This is why it is essential to analyze the impacts of each new ATP as soon as it is published in order to anticipate the necessary adaptations before it comes into effect.

What Impacts on SDS, UFI and PCN Notifications?

The consequences of a new ATP are not limited to the classification of substances. Depending on the case, a regulatory change may require updating several elements essential to product compliance:

• Safety Data Sheets (SDS);
• CLP labels;
• Unique Formula Identifiers (UFI);
• notifications to Poison Centers (PCN).

The challenge is to ensure consistency across all these documents. A modification to the classification of a substance or the content of an SDS must be reflected in other regulatory information to ensure product compliance throughout its lifecycle.

This consistency is particularly important for PCN notifications, which enable poison centers to quickly access the information needed to identify a mixture in an emergency. Outdated or inconsistent data may require updating notifications to maintain their compliance.

Why Paint and Coating Manufacturers Are Particularly Affected

The paints and coatings sector has several regulatory specificities that require particular attention when applying the CLP Regulation.

Depending on formulations, uses or marketing methods, certain provisions may modify applicable requirements. Colorants, paints tinted at point of sale, or the marketing of the same product under different references illustrate this complexity.

In addition, manufacturers often manage a large portfolio of formulations. When a new ATP is published, it is not just a matter of identifying the substances concerned. It is also necessary to assess the consequences for all products containing them, then organize regulatory updates within the required timeframes.

Mastering these specificities is essential to ensure product compliance in all markets.

Anticipating Future ATPs and Regulatory Updates

The implementation of a new ATP represents an important regulatory deadline, but above all an opportunity to adopt a more structured approach to compliance.

Rather than handling each change on a case-by-case basis, manufacturers have every interest in establishing a process that enables them to quickly assess the impacts of each new publication on their product portfolio.

This approach may include:

• identifying formulations affected by new harmonized classifications;
• assessing impacts on SDS, CLP labels, UFI and PCN notifications;
• prioritizing updates based on regulatory deadlines;
• verifying the application of provisions specific to the paints and coatings sector.

This organization is particularly useful for companies that manage numerous formulations or market their products in multiple markets. It enables better anticipation of future CLP Regulation changes, as already demonstrated by the draft ATP24.

Faced with the proliferation of regulatory requirements and the number of formulations to manage, manual approaches can quickly become complex. Digital solutions enable data centralization, easier impact analysis and automation of part of the document updates. Teams thus gain efficiency while reducing the risks of error and non-compliance.

Key Takeaways

Adaptations to technical progress (ATPs) of the CLP Regulation regularly update the harmonized classifications of hazardous substances. For paint and coating manufacturers, these changes can have repercussions on formulations, SDS, CLP labels, UFI and PCN notifications.

ATP23 provides a concrete example of this approach. Applicable from February 1, 2027, it introduces 22 new harmonized classifications and 10 modifications to existing classifications, which may impact certain formulations and their associated regulatory information.

Centralized management of compliance data and processes helps maintain consistency of regulatory information, reduce non-compliance risks and prepare more confidently for future CLP Regulation changes.

Download Our Practical Guide

Understanding ATPs is a first step. Anticipating their impacts on your formulations is another.

Our guide dedicated to paint and coating manufacturers helps you anticipate CLP Regulation changes and prepare your next regulatory updates.

You will discover in particular:

• the impacts of ATPs on your products;
• the regulatory specificities of the sector;
• best practices for managing SDS, UFI and PCN notifications;
• recommendations for structuring your compliance approach.