The CLP mixtures deadline of 1 May 2028 is already shaping work on the bench today. Under Commission Delegated Regulation (EU) 2023/707, the EU added six new hazard classes to the Classification, Labelling and Packaging (CLP) Regulation. New mixtures have been in scope since 1 May 2026, and existing mixtures already on the market must comply by 1 May 2028. Because a mixture's classification depends on how its constituent substances are classified, and substances are being reclassified now, formulators of cleaning products, coatings, adhesives, and detergents cannot treat 2028 as a future problem.
If you want a structured view of your exposure before supplier data starts arriving, you can request a compliance review to see where reclassification will touch your formulations.
Key Takeaways
📌 Delegated Regulation (EU) 2023/707 adds six new hazard classes to CLP for endocrine disruption, persistence, bioaccumulation, mobility, and toxicity.
⏳ The CLP mixtures deadline is 1 May 2028 for existing mixtures; new mixtures have been in scope since 1 May 2026.
🔗 Mixture reclassification depends on substance classification, so supplier data feeds everything downstream.
📄 Every affected mixture needs a formulation SDS update and, where classification changes, label changes.
⚠️ Most new-class classifications are currently self-classifications, increasing reliance on accurate supplier declarations.
🏭 Formulators in detergents, coatings, adhesives, and cleaning chemistries carry the heaviest load.
🤖 Substance-to-mixture traceability at scale is difficult manually and is a strong case for compliance automation.
What the CLP Mixtures Deadline Actually Means
CLP, Regulation (EC) No 1272/2008, is the EU framework that governs how chemical substances and mixtures are classified, labelled, and packaged before they are placed on the EU market. Delegated Regulation (EU) 2023/707 expanded that framework by introducing hazard classes that previously existed in other EU laws but had no formal home in CLP itself.
The practical effect is that substances and mixtures must now be assessed against new endpoints covering endocrine disruption, persistence, and mobility. For a fuller view of how this sits alongside other chemical rules, see Certivo's chemical and hazmat compliance solution and the related REACH framework page.
The Six New CLP Hazard Classes
New hazard class | Short form | What it assesses |
|---|---|---|
Endocrine disruption for human health | ED HH (Cat 1, Cat 2) | Effects on the human endocrine system |
Endocrine disruption for the environment | ED ENV (Cat 1, Cat 2) | Effects on wildlife and ecosystems |
Persistent, Bioaccumulative, Toxic | PBT | Long-lived substances that accumulate and harm |
Very Persistent, Very Bioaccumulative | vPvB | Extreme persistence and accumulation |
Persistent, Mobile, Toxic | PMT | Substances that travel through water systems |
Very Persistent, Very Mobile | vPvM | Extreme persistence and mobility in water |
Source for the hazard classes and legal basis: EUR-Lex, Delegated Regulation (EU) 2023/707 and ECHA, Understanding CLP.
Key Dates: Substances First, Then Mixtures
The regulation sets staggered dates. Substances move first, mixtures follow. This sequencing is deliberate and is the reason the CLP mixtures deadline cannot be managed in isolation.
Scope | New items placed on market from | Existing items transitional until |
|---|---|---|
Substances | 1 May 2025 | 1 November 2026 |
Mixtures | 1 May 2026 | 1 May 2028 |
As of late 2026, the transitional window for existing substances has closed, which means substance classifications under the new hazard classes should now be flowing through supplier safety data sheets. For formulators, the clock on existing mixtures runs to 1 May 2028, but the input data arrives across 2026 and 2027. Teams that treat May 2028 CLP as a standalone end-date risk discovering late that their mixture classifications were never based on updated substance information. Confirm the precise transitional provisions against the regulation text on EUR-Lex for your specific placing-on-market scenario.
CLP mixtures deadline timeline from 2025 to May 2028 for substances and mixtures
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Who Is Affected
The new hazard classes apply across the chemical supply chain, but the weight falls differently by role.
🏭 Formulators and downstream users. Producers of detergents, surface cleaners, industrial and decorative coatings, construction adhesives, and sealants must re-examine every mixture that contains a substance now classifiable under the new classes.
🔗 Importers. Companies placing mixtures on the EU market from outside the EU hold the same classification and labelling obligations as EU manufacturers.
📄 Substance suppliers. Manufacturers and importers of substances must self-classify and communicate updated classifications downstream, typically through the safety data sheet.
Formulators serving both consumer and professional markets face added complexity because the same base chemistry may appear across many finished products. Certivo's work with chemical manufacturing and consumer goods teams reflects how a single reclassified raw material can ripple across an entire catalogue.
Why the May 2028 Deadline Starts Now
Mixture classification under CLP generally relies on the classification of the substances inside the mixture. For the new hazard classes, a mixture is typically classified when it contains a substance classified as ED, PBT, vPvB, PMT, or vPvM at or above the applicable generic concentration limit. Based on currently available regulatory guidance, those generic concentration limits are commonly cited as 0.1% for Category 1 endocrine disruptors and for PBT, vPvB, PMT, and vPvM, and 1% for Category 2 endocrine disruptors. Confirm the exact values and any calculation rules against ECHA guidance and the regulation annexes before applying them.
This creates a dependency chain. A formulator cannot finalize a mixture's classification until the constituent substances carry their updated classifications. There is a second complication: most new-class classifications are currently self-classifications, because harmonised entries in CLP Annex VI for these endpoints are still limited. That places the burden of accuracy on the data moving through the supply chain.
The operational consequence is clear. The mixture reclassification work of 2027 and 2028 can only be as good as the substance data collected in 2026 and 2027. Teams that centralize that incoming data early avoid a compressed, error-prone scramble near the deadline. Certivo's proactive compliance risk use case and supplier documentation workflows are built around exactly this type of upstream-to-downstream data flow.
CLP mixture reclassification workflow from substance data to updated formulation SDS
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What Formulators Must Do Before 1 May 2028
The work breaks into a sequence that can start before every substance classification has arrived.
Build a substance inventory per mixture. Map every substance in every mixture back to a current CAS number and supplier. This substance-to-mixture map is the foundation for reclassification.
Collect updated substance classifications. Gather current safety data sheets and classification data from suppliers, and track which substances now carry ED, PBT, vPvB, PMT, or vPvM classifications.
Re-run mixture classification. Apply the generic concentration limits and calculation rules to determine whether each mixture triggers a new hazard class.
Complete each formulation SDS update. Update safety data sheet sections affected by the new classification, including hazard identification and composition information.
Revise labels where classification changes. Where a mixture's classification changes, update hazard pictograms, signal words, and hazard statements before placing affected stock on the market.
Prioritize by exposure. Sequence the work so the highest-volume and highest-risk mixtures are reclassified first.
For teams managing this across large product portfolios, BOM-level compliance tracking connects each finished mixture to the substances and suppliers that determine its status, so a single substance reclassification can be traced to every product it affects.
Documentation, SDS, and Audit Readiness
CLP compliance is ultimately an evidence problem. When a market-surveillance authority or a customer asks why a mixture is classified a certain way, the formulator must show the underlying substance data, the classification logic, and the dates on which decisions were made.
Audit readiness here means more than a current SDS. It means being able to answer point-in-time questions: which substance classification was used, which supplier declaration supported it, and when the formulation SDS update was issued. Immutable records, time-stamped declarations, and historic state tracking turn a reclassification exercise into defensible evidence. Certivo's audit-readiness use case and its broader materials and environmental compliance solution are designed to retain this evidence chain rather than recreate it under deadline pressure.
Compliance Risk and Enforcement Exposure
CLP is enforced by EU member states through national authorities and market surveillance. Non-compliant classification, labelling, or safety data sheets can lead to corrective actions, product withdrawals, and penalties that vary by member state. Beyond regulators, downstream customers increasingly require accurate, current documentation as a condition of supply, and a missing or outdated SDS can stall orders.
The risk concentrates in the gap between when substance data changes and when the mixture is reclassified. A substance quietly reclassified by a supplier, if not captured, can leave a mixture mislabeled for months. This is why continuous monitoring of supplier certifications and classifications, rather than periodic manual checks, matters for the CLP mixtures deadline. Certivo's regulatory change and horizon-scanning capabilities are intended to flag such shifts as they surface.
How AI and Automation Help Manage Mixture Reclassification
The core challenge is scale and traceability. A mid-sized formulator may hold hundreds of mixtures built from thousands of substance-supplier combinations. Manually reconciling incoming safety data sheets against each formulation is slow and prone to gaps.
AI-native compliance automation addresses the structural work. Certivo acts as a centralized compliance data backbone that holds substance, supplier, and mixture relationships in one place. CORA-powered regulatory intelligence can parse incoming supplier documents, extract classification data, and flag where a substance reclassification changes a mixture's status. That shifts the effort from manual document review toward exception handling.
The practical outcome aligns with the CLP CTA formulators care about most: tracing mixture classifications back to the reclassified substances that drive them, across the full portfolio, without rebuilding the map by hand each time a supplier updates a sheet. For context on how AI fits into this work, see AI tools for compliance management.
Executive Takeaway
The CLP mixtures deadline of 1 May 2028 is a data-sequencing problem before it is a labelling problem. Substance classifications are moving through the supply chain now, and every affected mixture will need reclassification, a formulation SDS update, and, where status changes, a new label. Organizations that centralize supplier data early and keep a traceable link between substances and mixtures will meet the deadline with evidence intact. Those that wait will compress the work into a high-risk window.
To understand where new CLP hazard classes will touch your formulations, and to trace mixture classifications back to their reclassified substances, speak with a compliance specialist or request a compliance risk assessment.
Hariprasanth
Hariprasanth is a Chemical Compliance Specialist with nearly four years of experience, underpinned by a degree in Chemical Engineering. He brings in-depth expertise in global product compliance, working across key regulations such as REACH, RoHS, TSCA, Proposition 65, POPs, FMD, and PFCMRT.
Hariprasanth specializes in reviewing technical documentation, validating supplier inputs, and ensuring that products consistently meet regulatory standards. He works closely with cross-functional teams and suppliers to collect accurate material data and deliver clear, audit-ready compliance reports that stand up to scrutiny.
Through his strong analytical skills and regulatory insight, Hariprasanth enables organizations to navigate evolving compliance challenges while aligning with sustainability initiatives in an increasingly dynamic regulatory environment.