23rd ATP to CLP: Key Substance Updates and Compliance Timeline
On June 20, 2025, the European Union released the 23rd ATP to CLP. This update adds and amends substances on the Annex VI list of harmonised classifications. The goal is to improve hazard communication by ensuring stakeholders clearly understand chemical risks and can take appropriate measures to reduce them.
Everything You Need to Know About the 23rd ATP to CLP
The update introduces 22 new harmonised classifications. Among these are dinitrogen oxide and the preservative MIT HCl. Dinitrogen oxide, commonly used in the packaging industry (and sometimes illicitly), now carries a controversial Reproductive Toxin 1B classification. It is also facing restriction under the entry 30 list. MIT HCl, a widely used preservative, now has a 0.0015% specific concentration limit (SCL) for Skin Sensitiser 1A, similar to substances like CMIT/MIT. This change may significantly affect the concentrations allowed in products and often triggers extra labelling requirements under the BPR.
In addition to the 22 new entries, the ATP amends 10 existing classifications. This includes the preservative IPBC, which now has its Acute Toxicity by Inhalation upgraded from category 3 to 2. The new classification also introduces an ATE value for the dust/mist exposure route.
Timeline for Compliance and Adaptation
23rd ATP to CLP will apply from February 1, 2027. This transition period gives suppliers time to update labels and packaging to meet the new rules. Authorities encourage early compliance to ensure strong protection for both human health and the environment. During this period, suppliers should review their inventory and update safety data sheets (SDS) and labels accordingly.