TL;DR:
The EU CLP regulation now includes mandatory hazard classes for endocrine disruptors (ED), PBT/vPvB, and PMT/vPvM. New substances must already comply. Existing substances by November 2026. Existing mixtures by May 2028. For large portfolios, these deadlines require portfolio-wide SDS updates. Cloud platforms with mass recalculation handle this through automated workflows.
The EU’s CLP regulation was updated by Delegated Regulation 2023/707 to introduce hazard classes not previously in European chemical regulation.
| Hazard Class | What It Covers | SDS Impact |
| ED HH | Interferes with hormonal system, adverse human health | New Section 2 + updated hazard statements |
| ED ENV | Interferes with endocrine systems of wildlife | New environmental data in Section 12 |
| PBT / vPvB | Persistent, bioaccumulative, toxic | Section 2 + 12 updates; exposure scenarios |
| PMT / vPvM | Persistent, mobile in water systems | New classification; full SDS updates |
| KEY TAKEAWAY |
| Four new hazard class categories: ED HH, ED ENV, PBT/vPvB, PMT/vPvM. Addresses hazards the original CLP framework did not cover. |
| Deadline | Applies To | What Must Happen |
| May 2025 (now) | New substances | Classify for ED, PBT/vPvB, PMT/vPvM |
| May 2026 | New mixtures | All new mixture SDSs must include new data |
| November 2026 | Existing substances | Portfolio-wide reclassification + SDS/label regeneration |
| May 2028 | Existing mixtures | Final wave — every SDS, label, language |
Source: CMS Law CLP update analysis
| KEY TAKEAWAY |
| Four waves: May 2025 through May 2028. November 2026 for existing substances is the highest-impact milestone. |
Every existing substance must be evaluated against new criteria. A €122M+ coatings manufacturer with 15,000+ products handles this through mass recalculation on cloud SDS: 500,000 items in 25 minutes. For large portfolios, total document volume reaches tens of thousands.
| KEY TAKEAWAY |
| November 2026 creates a cascade: reclassified substances → mixtures → SDSs → labels → redistribution. Mass recalculation is the only viable approach at scale. |
ED: Bisphenols, phthalates, parabens, some pesticides.
PBT/vPvB: Many PFAS. See also EU PFAS restriction.
PMT/vPvM: Short-chain PFAS, pharmaceutical residues, water-soluble persistent chemicals.
Latest CLP Annex VI update: 22 new + 10 revised substances.
| KEY TAKEAWAY |
| ED, PBT/vPvB, PMT/vPvM candidates include bisphenols, phthalates, many PFAS, and persistent chemicals. The list will grow. |
Regulatory update: Vendor pushes updates.
Substance screening: Automated.
Mass recalculation: All jurisdictions.
SDS/label regeneration: 47 languages.
Distribution: Audit-ready.
One chemical importer: 25%+ faster SDS creation, zero manual data entry, operational in under a week.
| KEY TAKEAWAY |
| Five-step automated workflow: update → screening → mass recalculation → regeneration → distribution. No manual intervention. |
PFAS evaluation (end 2026): many PFAS are PBT/vPvB and PMT/vPvM candidates. REACH enforcement: 313 checks, 30% referred. ECHA SDS quality: 35% non-compliant. OSHA HazCom 2025: parallel US obligations.
| KEY TAKEAWAY |
| November 2026 sits in the middle of overlapping CLP, PFAS, REACH, and HazCom deadlines. Unified SDS management, not separate projects. |
Assess exposure. Focus on ED, PBT/vPvB, PMT/vPvM candidates.
Estimate cascade volume. Substances × mixtures × jurisdictions × languages.
Evaluate system capacity. Can it mass-recalculate? Regenerate in 47 languages? Audit-ready distribution?
Implement Q1–Q2 2026. Standard: 5 business days.
Time to spare before November 2026.
| KEY TAKEAWAY |
| Screen, estimate, evaluate, implement. 5 business days. The window before November 2026 is finite. |
CLP November 2026: Is Your SDS System Ready?
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