As you may know, the European Union introduced new hazard classes for chemicals under Commission Delegated Regulation (EU) 2023/707. The transitional period for substances placed on the EU market before 1 May 2025 and already in the supply chain will end on 1 November 2026.
From this date, these substances must be classified and labelled in accordance with the new hazard classes, where applicable. Substances placed on the EU market on or after 1 May 2025 have already been subject to these requirements.
The new hazard classes introduced by Commission Delegated Regulation (EU) 2023/707 are as follows:
Hazard class | Hazard statement codes |
Endocrine disruption (ED) for human health | EUH380/EUH381 |
Endocrine disruption (ED) for the environment | EUH430/EUH431 |
Persistent, bioaccumulative and toxic (PBT) / Very persistent and very bioaccumulative (vPvB) | EUH440/EUH441 |
Persistent, mobile and toxic (PMT) / Very persistent and very mobile (vPvM) | EUH450/EUH451 |
Impact on REACH Registration Dossiers
- Since spring 2024, ECHA has made the new hazard classes available in IUCLID. These classes can therefore be included in REACH registration dossiers.
- After the applicable transitional period ends, it will be mandatory to indicate whether a substance is classified in any of the new hazard classes. Where a registrant decides to change the substance’s self-classification and labelling, the REACH registration dossier must be updated within six months of that decision.
- If a substance does not meet the criteria for classification under a particular hazard class, the reasons for this conclusion should be included in the registration dossier.
ECHA’s IUCLID validation rules include quality checks for the new hazard classes. The option “hazard class not assessed” will no longer be accepted after the applicable transitional period. However, quality warnings do not automatically result in technical completeness check failures.
What Should Companies Do?
Existing REACH registration dossiers should be reviewed before 1 November 2026. Companies should ensure that the substance’s CLP classification, safety data sheet and REACH registration dossier are consistent. The dossier should also accurately reflect the outcome and basis of the assessment against the new hazard classes.
Please also note that the transitional period for mixtures placed on the EU market before 1 May 2026 and already in the supply chain will end on 1 May 2028.
Chemleg can support your company throughout this process.
You can benefit from the following services under EU CLP:
