Chemical compliance

What’s happening? Here is an update for June 2025:

EU REACH Revision: analysis of draft proposal
EU Classification, Labelling and Packaging: Labelling guidance
Microplastics in cosmetics: use, environmental impact and regulation

EU REACH Revision: analysis of draft proposal

May’s COMPASS shared the news that the European Commission circulated a set of draft REACH revision ‘simplification’ documents in April’s Competent Authorities meeting.

H2 Compliance’s Chemical team has analysed the details of the proposal, and its implications for the industry, in a series of articles on its website:

EU REACH Revision: Changes to Registration & Data Sharing
EU REACH Revision: Proposed Changes to Chemical Information
Compliance and Evaluation – coming up
Risk Management: Authorisation and Restrictions – coming up

The team is expecting an impact assessment by July 2025 and a final legislative proposal to be circulated for legislative procedure and adoption by November 2025.

EU Classification, Labelling and Packaging: Labelling guidance

In some ways, labelling of hazardous products is even more important than the safety data sheets (SDS), which they must be aligned with, for informing the end user about product safety.

Labels are essentially a concise and visual representation of the key information contained within the SDS.

The clear, visual indicator must inform the end-user about the hazards of the product contained within the package or container.

Comprehensive guide

H2 Compliance’s hazard communications team has published a comprehensive guide to suppliers on how to comply with the labelling requirements set out in the revised EU CLP Regulation (EU) 2024/2865 that entered into force in December 2024.

It provides guidance on the most significant new requirements, as well as general requirements from the previous version of the regulation, including:

Update on fold-out labels
New 6-month deadline for updating labels
Introduction of a minimum font size
New required label characteristics
Update on digital labels, and
General overview of required label elements

Timeline

The obligations will generally apply from 1 July 2026. However, some rules, such as those on label formatting, are applicable from 1 January 2027.

Substances and mixtures placed on the market before these dates do not need to be re-labelled and re-packaged based on the new rules.

They can continue to be in the supply chain until 1 July 2028 and 1 January 2029 respectively.

Microplastics in cosmetics: use, environmental impact and regulation

Microplastics – defined in the EU as ‘synthetic polymer particles (SPMs), < 5mm’ – have become a significant environmental concern, particularly in the cosmetics and personal care industry.

These tiny plastic particles are used in various beauty and skincare products for their exfoliating properties, texture enhancement and prolonged shelf life.

However, their persistence in the environment and potential harm to marine ecosystems have led to increasing regulatory scrutiny worldwide.

Compliance strategies

To comply with regulations and reduce environmental harm, cosmetic companies can voluntarily phase out SPMs and turn to sustainable alternatives to microplastics, including: