CLP: Towards Alignment with the Latest GHS Revisions
The EU is proposing changes to the CLP Regulation to align it with the latest GHS revisions.
On 17 August 2026, the European Union notified the World Trade Organization (WTO) of a draft Delegated Regulation proposing amendments to Annexes I, III, IV, V, VI and VIII of the CLP Regulation.
The objective is to align the EU CLP framework with GHS Revisions 8, 9 and 10, while also partially incorporating elements from Revision 11. Although the regulation is still at the draft stage, these proposed changes provide an early indication of how EU classification and labelling requirements could evolve.
GHS Revisions 8, 9 and 10: What Could Change?
The proposed amendments would introduce several important changes, including:
- New classification criteria and hazard communication elements for chemicals under pressure, including provisions addressing explosion risks outside transport configurations.
- Revised and rationalised precautionary statements to make hazard information clearer and easier to understand.
- Greater use of non-animal testing methods for assessing health hazards associated with certain hazard classes.
- New provisions for in vitro, ex vivo and other non-animal methods when assessing skin corrosion and irritation.
- Updated approaches for metals and metal compounds, including classification strategies, guidance and tools related to long-term aquatic toxicity.
What About GHS Revision 11?
The draft also partially incorporates GHS Revision 11. At this stage, the proposed changes concern classification criteria and provisions relating to aerosols and skin-sensitising mixtures.
The partial implementation is intended to avoid unnecessary administrative burden. It would reduce the need to revise the same provisions twice within a short period following the implementation of GHS Revisions 10 and 11.
Preparing for Regulatory Change
While the proposed amendments are still under discussion, Lisam’s regulatory and development teams are already assessing the draft requirements, analysing their potential impact on our solutions and preparing for the necessary updates.
This proactive approach helps us prepare for the changes ahead and support our customers as the new requirements move towards implementation.
What Happens Next?
Interested parties can submit comments on the draft until 16 October 2026.
Following publication in the Official Journal of the European Union, the Delegated Regulation would enter into force 20 days later. Mandatory application would then begin after a 24-month transition period, while products already placed on the market would benefit from a 48-month transitional period.
Want to know how these changes could affect your classification and labelling processes?
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