21 October 2024
New CLP Regulation (EU) 2024/2865: Key Changes and Implications for the Cosmetic Industry
December 2024 - The updated CLP Regulation (EU) 2024/2865 introducing significant changes with potential implications for the cosmetic industry.
The new version of the CLP (Classification, Labelling, and Packaging) Regulation, Regulation (EU) 2024/2865, entered into force on December 10th, 2024 and introduces several changes that could impact the cosmetic industry. Published on November 20, 2024, the regulation updates previous provisions of the CLP Regulation (EC) No. 1272/2008
Finished cosmetic products are exempt from the requirements under the CLP Regulation, as they fall under the Cosmetics Regulation (EC) No 1223/2009, which has its own labelling and safety requirements. However, the new CLP amendments will still impact non-cosmetic products such as candles, or cosmetic raw materials suppliers and cosmetic manufacturers.
The requirement for labelling updates (e.g., font size, spacing, etc.) directly applies only to the upstream supply chain of cosmetic ingredients, not the finished cosmetic products themselves.
These changes will come into effect in stages, with key provisions applying from July 1, 2026, and others, such as detailed labelling rules, by January 1, 2027.
Summary of Key Differences from the Previous CLP Regulation
- New Hazard Classes: The updated regulation incorporates hazard classes for endocrine disruptors (Eds), and persistent, mobile and toxic substances (PMTs).
- Labelling Requirements :
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- Stricter rules for font size, spacing, and color to ensure legibility.
- Introduction of digital labelling options for non-critical safety information.
- Rules for updating labels within specific deadlines when classifications change.
- Classification of Complex Substances: Specific criteria have been established for multi-component or natural-origin substances (aka MOCS), e.g. essential oils, addressing challenges in classifying these types of ingredients that are mixtures of chemical substances.
- Online Sales and Supply Chain Accountability: Obligations have been expanded to ensure that chemical substances and mixtures sold online meet EU classification and labelling standards, even if supplied by non-EU entities.
- Digital Innovation: Provisions for digital labelling and better alignment of data-sharing requirements to enhance consumer access to safety information.
- Advertising Restrictions: Claims like “non-toxic” or “ecological” are now prohibited unless substantiated by compliance with new rules.
- Harmonised Classifications: Simplified processes to speed up adoption and updates of harmonised classifications.
Impact on the Cosmetic Industry
For cosmetic products
- Ingredient Classification:
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- Cosmetic raw materials (e.g., dyes, preservatives, fragrances) are subject to CLP classification. These ingredients could be reclassified under the updated criteria (e.g., as endocrine disruptors or PMTs)
- Supply Chain Communication:
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- Upstream suppliers of cosmetic ingredients must comply with the updated labelling and safety data sheet (SDS) requirements under CLP. This could lead to changes in the safety information provided to cosmetic manufacturers.
- Digital Labelling:
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- While cosmetic finished products are exempt, suppliers and manufacturers of raw materials might adopt digital labelling practices to streamline information sharing, potentially offering enhanced traceability and safety documentation.
For non-cosmetic products
- Ingredient Classification:
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- Non cosmetic formulations often include natural and synthetic substances that will require reclassification under the updated criteria, particularly for substances now recognized as endocrine disruptors or PBTs/PMTs.
- Packaging and Labelling:
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- Companies could need to redesign non-cosmetic product labels to meet new requirements related to the reclassification of their substances and mixtures (if applicable). They could also including digital labelling integration where permitted.
- Online Sales and Supply Chain Accountability:
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- Companies who sold online cosmetic raw materials, or mixtures in the scope of the CLP (e.g. candles), will have to ensure that chemical substances and mixtures sold online meet EU classification and labelling standards, even if supplied by non-EU entities.
Author
Christophe Brault-Chevalier
Christophe Brault-Chevalier is the Scientific & Regulatory Affairs Director at Biorius, bringing over 20 years of experience in the cosmetics industry. He has previously held positions at International Flavors & Fragrances Inc. (IFF) and LVMH, further enhancing his expertise in the field.
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