The European Commission wants to give binding CLP classifications to substances already identified as endocrine disruptors (ED), PBT or vPvB under REACH, the Biocidal Products Regulation or the Plant Protection Products Regulation. Its draft delegated regulation is open for feedback until 24 November 2026, midnight Brussels time.
If the act is adopted, suppliers of the listed substances, and of mixtures that contain them, will have to update safety data sheets and labels. It makes the hazard classes added to CLP in 2023 binding for named substances.
Over 100 substances would get harmonised ED, PBT or vPvB entries
The draft, known as the "transfer ATP", copies hazard identifications that other EU laws have already made into CLP Annex VI. No new assessment is done. Article 37(7) of CLP requires the transfer, in line with the Commission's "one substance, one assessment" reform.
- Scale: law firm Keller and Heckman estimated over a hundred substances in March 2026. The full list is in the 30-page annex published with the draft.
- Timing: CLP set a deadline of 11 June 2026 for the transfer, and the Commission missed it. Its initiative page still lists adoption as planned for Q2 2026.
- Contested entries: Bayer disputes the ED entries for flufenacet and metribuzin. EEB and PAN Europe argued in April for keeping biocides such as IPBC, iodine and zineb, and pesticides such as fludioxonil and cyprodinil, on the list.
A separate Commission initiative on the same transfer is running in parallel.
Expect changes to SDS Sections 2, 3, 11 and 12, and to labels
Suppliers cannot self-classify away from a harmonised entry in Annex VI. The new hazards also carry into mixtures that contain a listed substance.
- Section 2: add the ED, PBT or vPvB hazard classes and statements.
- Section 3: reflect the harmonised entry for each listed component.
- Sections 11 and 12: add the endocrine-disruption and persistence data behind the classification.
- Labels: add the new statements: EUH380/EUH381 (ED, human health), EUH430/EUH431 (ED, environment), EUH440 (PBT) and EUH441 (vPvB).
How long you get to comply is still open. The Commission's starting point is 18 months; EEB and PAN Europe argue six months is enough.
Check your inventory before feedback closes on 24 November
- Download the draft annex from the Have your say page and match it against your chemical inventory.
- List the mixtures that contain a listed substance above the relevant concentration limits.
- Submit feedback by 24 November 2026 if an entry affects your products or you think it is wrong.
- Schedule SDS and label revisions now, in case the final transition period is short.
Sources
- European Commission: Have your say, initiative 15632
- Keller and Heckman: Inclusion of over a hundred EDs and PBT/vPvB substances in CLP (March 2026)
- EEB and PAN Europe: Comments on the transfer ATP (April 2026)
Arysha Alif Khan
Arysha Alif Khan is an EHS and chemical safety specialist with a background in biochemistry, biotechnology, and public health. She works closely with the product and regulatory teams to turn complex chemical regulations, SDS requirements, and workplace safety standards into clear, practical guidance for people.