CLP: What coatings manufacturers must do now

CLP Regulation (EU) 1272/2008 is the keystone framework for the classification, labelling, and packaging of hazardous ­substances and mixtures in Europe. Delegated Regulation (EU) 2023/707 ­introduces new hazard classes into the system for the first time in many years.These new criteria apply directly to many substances used in the paints and coatings industry, including plasticisers, solvents, and ­various ­additives. Companies that fail to act promptly risk not only regulatory non-compliance but also supply chain disruption and loss of market access.

Endocrine disruptors for human health (ED HH) and the environment (ED ENV)

Endocrine disruptors are substances or mixtures that alter or disrupt hormonal systems in humans and animals. In humans, they are associated with cancer, diabetes, congenital malformations, and neurodevelopmental disorders. Comparable effects have also been documented in animals. Within the paints and coatings industry, the substances most likely to be affected include a number of phthalates used as plasticisers, along with selected UV absorbers and biocides. Of particular relevance to the environment are exterior coatings and architectural paints, ­because substances may leach out or run off into aquatic environments where they may exert hormonal effects.

PBT and vPvB substances

Substances classified as persistent, bioaccumulative, and toxic (PBT), or as very persistent and very bioaccumulative (vPvB), biodegrade slowly and may accumulate in the food chain and the environment. These substances have a very high potential to cause adverse effects in humans and animals. Chlorinated paraffins are a well-known example of PBT substances employed within the paints and coatings industry. Dibutyltin dilaurate (DBTL), widely used as a catalyst in polyurethane systems, is also subject to strict regulatory scrutiny.

PMT and vPvM substances

Substances that are persistent, mobile, and toxic (PMT), or are very ­persistent and very mobile (vPvM), do not accumulate to a significant extent in organisms. However, they remain persistent and mobile in the water cycle and can therefore pose a threat to drinking-water resources. The relevance to formulators is that certain short-chain solvents and ionic surfactants may meet the new PMT or vPvM criteria.

Classification criteria for mixtures

A mixture is classified as an endocrine disruptor (ED) for human health or the environment where at least one component has been classified as a Category 1 or Category 2 endocrine disruptor and is present at or above the appropriate concentration limit.

• Category 1 classification is triggered by a concentration limit ≥ 0.1% (for both human health and the environment).
• Category 2 classification is triggered by a concentration limit ≥ 1% (for both human health and the environment).

A mixture is classified as PBT, vPvB, PMT, or vPvM if at least one ­component of the mixture has been classified accordingly and is present at or above the concentration limit of 0.1% (see Table).

Timeline and transition periods

From 1 May 2025, substances placed on the market must be ­classified, labelled and packaged in accordance with the new ­hazard classes. A transition period applies until 1 November 2026 for ­substances already on the market before that date. For mixtures, this obligation begins on 1 May 2026, with a transition period lasting until 1 May 2028. The transition periods apply only to substances and mixtures that were already on the market before the respective application dates.

What this means in practice

For companies, the introduction of the new hazard classes means that they must thoroughly review the raw materials they use. They need to clarify whether substances have already been assigned to a new hazard class or are still subject to scrutiny. Key sources of information include supplier´s safety data sheets and ECHA databases. Where a raw material receives a new classification, the corresponding safety data sheets must be updated – particularly Section 2, as well as the toxicological and ecological data. Labels must also be revised. While the existing pictograms will remain, the hazard statements ­(H-statements) and precautionary statements (P-statements) must be updated. In some cases, the new classification may have broader implications. If usage restrictions or regulatory changes arise, it may be necessary to revisit the formulation and adjust it.

Conclusion

The introduction of the new hazard classes under Delegated ­Regulation (EU) 2023/707 marks one of the most significant expansions of the CLP Regulation since its creation. Substances that affect hormonal systems or persist in the environment and water cycle pose risks that were not fully addressed by previous hazard categories. The new classes now close this regulatory gap. For the paints and coatings industry, this creates a clear call to action requiring time and resources: raw material audits, updated safety data sheets and revised product labelling.

Early engagement with suppliers and regular monitoring of ECHA ­databases will help companies stay ahead. Businesses that ­proactively track their raw materials and adapt to new classifications will not only ensure legal compliance but will also strengthen their profile as ­reliable and responsible partners in the supply chain.

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