Upcoming regulatory changes for classification/labelling of chemicals, cosmetics and fertilisers
The VI Omnibus Package for chemicals is the latest in a series of Simplification Omnibus proposals presented under the current Commission mandate. It will be complemented by the forthcoming ECHA Basic Regulation, which will equip the European Chemicals Agency with the resources and flexibility needed to fulfil its expanding tasks, and by a VII Omnibus for plant protection products and an VIII Environmental Omnibus to further reduce administrative burdens.
These proposals are adopted under the ordinary legislative procedure, with Article 114 TFEU as their legal basis. They will therefore undergo full legislative scrutiny before adoption.
Industry stakeholders are strongly encouraged to engage in this process to help shape rules to ensure that simplification delivers its promised benefits. Please contact our EU Regulatory team for further information and assistance with the process: Koen Van Maldegem, Maud Grunchard, Simon Englebert, Maria Beatrice Grassi
On 8th July 2025, the European Commission published its Sixth Simplification Omnibus ("the VI Omnibus Package") alongside its Action Plan for securing the global competitiveness of the European chemicals industry and a proposal for a Regulation to support and reinforce the functioning of the European Chemicals Agency ("ECHA"). This marks the sixth cross-sector initiative designed to simplify, clarify and defer certain obligations under three main pieces of EU legislation: (i) the Classification Labelling and Packaging Regulation ("CLP") (ii) the Cosmetics Product Regulation ("CPR") and (iii) the Fertilising Product Regulation ("FPR").
The VI Omnibus Package aims to make chemical legislation more effective and cost-efficient for industry, responding directly to the calls in the Letta and Draghi reports, which highlighted excessive regulatory burdens as barriers to innovation and competitiveness. It also builds on feedback collected during the Commission's Reality Check consultations held in May 2025 with stakeholders across the three affected regulations.
This article analyses the key changes brought by the VI Omnibus Package under each Regulation.
CLP
Postponements to Regulation (EU) 2024/2865
Regulation (EU) 2024/2865 introduced specific rules on the formatting of labels, deadlines for re-labelling in case of classification changes, information requirements for advertisements and distance sales offers and labelling requirements for fuelling stations. During the stakeholder consultations, industry repeatedly called for a pause on some of these provisions due to disproportionate administrative burdens and compliance costs.
In response, the VI Omnibus Package proposes deferring the date of application for several obligations under Regulation 2024/2865. Specifically, the requirements for updating hazard information on labels (Article 30 CLP), advertising (Article 48 CLP), distance sales (Article 48a CLP), labelling of fuel pumps (Annex II CLP) - initially scheduled to apply by 1 July 2026 - and the label formatting rules (Article 31(3) and Annex I CLP) - initially scheduled to apply by 1 January 2027 - will now apply from 1 January 2028. For these deferred obligations, voluntary early application will no longer be permitted.
Substantial amendments to CLP
The VI Omnibus Package also introduces a range of substantive changes to streamline the CLP.
A new definition of digital contact is added (Article 2(42) CLP) — "any up-to-date and accessible online communication channel through which a supplier can be reached or engaged without the need to register or download an application." Section 1.6 of Annex I CLP is updated accordingly to support the EU's 'digital by default' objective, improving communication between suppliers, end-users, and national enforcement authorities.
Article 29(2) CLP is amended to allow economic operators to reduce the information required on labels for packaging containing smaller quantities of substances or mixtures, without needing to demonstrate that the packaging's size or shape makes full labelling impractical. Related clarifications are made to section 1.5.2.4 of Annex I CLP for 10 ml packaging, particularly for less hazardous products.
Furthermore, Article 30 CLP is amended so that labels must now be updated without undue delay once new data is obtained or communicated to the supplier, replacing the fixed six-month timeframe, which was deemed impractical.
The amendment to Article 31(3) CLP removes mandatory label formatting rules introduced by Regulation 2024/2865 (i.e. to format according to section 1.2.1 of Annex I CLP, as they were found to be costly and restrictive for economic operators).
Articles 48 and 48a CLP on advertisements and online sales are narrowed in scope to apply only to chemicals sold to the general public.
Part 5 of Annex II CLP is amended to simplify labelling requirements for fuelling stations. Certain label elements, such as the nominal quantity and the unique formula identifier ("UFI"), will no longer be required on fuel pumps, helping suppliers comply more easily without compromising safety.
Cosmetics
A new Article 14a CPR introduces a procedure to allow colourants, preservatives, and UV filters to be added to Annexes IV to VI CPR. Manufacturers can submit a request with scientific evidence showing that the substance is safe in light of the latest technical and scientific knowledge. The Commission will then seek an opinion from the Scientific Committee on Consumer Safety ("SCCS"), which must deliver its opinion within 12 months, extendable if more data is needed.
Article 15 CPR is amended to streamline derogation conditions for using substances classified as CMR (Carcinogenic, Mutagenic, or toxic for Reproduction) category 1A or 1B. The burden of proving food safety is removed, recognising that food and cosmetics are distinct product categories. Derogation requests must be submitted within three months of a new CMR classification under the CLP. The Commission will only grant a derogation where no safer, functionally equivalent, and technically feasible alternatives exist, and the SCCS confirms safety for the intended cosmetic use. The amendments clarify that the presence of a CMR-classified constituent in a natural complex substance does not automatically trigger a ban; the SCCS will assess overall safety. Furthermore, if a substance poses a CMR risk only through ingestion or inhalation, it should not be banned for dermal use. Transitional periods apply: affected cosmetic products may be placed on the market for up to 12 months and sold for up to 24 months after the ban enters into force.
Article 16 CPR is amended to remove pre-notifications of cosmetic products containing nanomaterials six months before placing them on the market, currently required in addition to notification of cosmetic products to the Commission.
Article 22 CPR is updated to remove the obligation for Member States to review and report on their market surveillance activities every four years, avoiding duplication given the role of the Information and Communication System for Market Surveillance ("ICSMS").
Finally, Article 33 CPR establishing a glossary of common ingredient names is deleted to allow reliance on internationally recognized nomenclature instead.
Fertilisers
The main amendment under the FPR concerns Annex II, Part II, Component Material Category ("CMC") 1, point 2. The requirement for all substances used in EU fertilising products to be registered under the REACH Regulation will be deleted. Instead, the general obligations under REACH will apply — notably the principle in Article 1(3) REACH, which places the responsibility on manufacturers, importers, and downstream users to ensure that their substances do not adversely affect human health or the environment. This upholds the fundamental no data, no market rule under Article 5 REACH.
The amendments also strengthen the shift towards digitalisation of information and reporting obligations. They require that the EU declaration of conformity must now be prepared in electronic form and made accessible online or via a data carrier. Economic operators must indicate a 'digital contact' on their products to improve communication with national authorities — a role that the European Business Wallet is expected to support once operational. Reporting to national authorities will move fully to electronic submission, and all documents exchanged with notified bodies for conformity assessments must also be digital. Where digital labels are used, they must link directly to the declaration of conformity. In addition, when products are covered by other EU laws that require a digital product passport, the declaration of conformity and any digital labelling must also be made available through that passport.
Article 42 FPR will empower the Commission to adopt criteria and a methodology for assessing micro-organisms used in microbial plant biostimulants other than those already listed in CMC 7. This will ensure they pose no risk to human, animal, or plant health, safety or the environment, and deliver agronomic efficiency. These criteria must consider elements detailed in the new Article 42(4a). The existing empowerment in Article 42(4) is retained, but the word "only" will be deleted to allow parallel empowerments for amending CMC 7.
Finally, Article 43 will be deleted to allow the Commission to adopt delegated acts amending multiple component materials simultaneously.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
