Simplification of certain requirements and procedures for chemical products
In July 2025, the European Commission released its simplification package for the chemical industry, the so-called 6th Omnibus. The aim is to further streamline and simplify key EU chemicals legislation, reducing compliance costs and administrative burdens for the chemical industry, while ensuring strong protection of human health and the environment.
The measures include simplifying hazardous chemical labelling rules, clarifying EU cosmetics regulation, and easing registration for EU fertilising products by aligning information requirements with standard REACH rules for chemicals. The full set of legislative documents is available here.
The European Commission has highlighted that the chemicals sector is vital to Europe’s economy, underpinning the manufacture of almost all goods and providing essential materials and technologies to industries that support the welfare, security and resilience of European economies.
We have taken a deeper dive into the regulatory developments proposed for the Classification & Labelling and Cosmetics regulations.
CLP Regulation
The chemical industry has identified numerous difficulties in implementing some of the new rules after the publication of the revised CLP regulation. Therefore, the Chemical Industry Action Plan also aims to simplify certain provisions of Regulation (EC) No 1272/2008 while maintaining the same level of protection for human health and the environment.
On 16 May 2025, the European Commission held a Reality Check to gather practical feedback on the revised CLP Regulation. Stakeholders were invited to share concrete experiences and proposals on how to make the new rules more workable.
This initiative is being considered primarily due to its financial impact on EU businesses and the need to maintain their competitiveness.
In summary, the crucial aspects are:
- Simplification of label formatting rules (Article 31(3) and section 1.2.1 of Annex I)
This initiative is seeking to allow more flexible formatting rules laid down for labelling of hazardous chemicals, including mandatory minimum font sizes and line spacing, as these were identified to be costly and restrictive for industry. The new rules ease these requirements, focusing on keeping labels clear and readable rather than enforcing rigid formatting rules.
- Clarification of labelling requirements for small packaging, especially for very small containers under 10 mL (Article 29(2) and section 1.5.2.4 of Annex I)
The change will allow economic operators to reduce the information required to be provided on labels for packaging containing smaller quantities of chemical substances or mixtures. This can be done without the need to prove that this packaging is either in such a shape or form or is so small that it is impossible to meet full labelling requirements.
- Removing fixed deadline for the obligation to update the label (Article 30(1))
The amendment suggests removing fixed six-month deadline for updating the label, while maintaining the more flexible requirement to ensure the label is updated without undue delay, as the period of six months appeared to be impossible to comply with in the case of complex supply chains.
- Revision of advertisements and online sales rules amended to reduce their scope to chemicals sold to the general public (Articles 48 and 48a)
Hazardous substances and mixtures traded between professionals are already subject to information requirements under Regulation (EC) No 1907/2006, so additional rules would not be proportionate.
Furthermore, amended Article 48 simplifies information requirement in advertisements aimed at general public. The amended provisions will require advertisements of chemicals to encourage customers to read the label and product information before use.
- Introduction of the definition ‘digital contact’ (Article 2)
Instead of current requirements for economic operators to indicate their address and telephone number on the label of the packaging of hazardous substance or mixture, the amendment requires providing an address and a digital contact, which could be any up-to-date and accessible online communication channel through which economic operators can be reached or engaged.
- Expanding the use of digital labelling (section 1.6 of Annex I)
Suppliers will be able to include extra contact information on digital labels instead of the physical label, saving space on physical labels and making it easier to manage and update product details using digital technology.
- Simplification of labelling requirements for fuelling stations (part 5 of Annex II)
Some label elements, such as nominal quantity and UFI, will not be required on fuel pumps, helping fuel suppliers meet the requirements without lowering safety standards.
Cosmetic Regulations
The Chemical Industry Action Plan contains a simplification package for the Cosmetic Regulation (EC) No 1223/2009. EU companies have long seen overregulation, with its obstacles and administration as their greatest burden.
The Reality Check (16 May 2025) saw these proposed measures to the regulation as removing unnecessary administrative burdens and streamlining the procedures for ingredient approvals and notifications, allowing industry to shift the financial and human resources from compliance and administrative tasks to R&D and innovation. The changes will allow the EU cosmetic businesses (of which 98% are SMEs) to scale up and be more competitive on the EU and global arena. At the same time high safety standards will be maintained and digitalisation for better efficiency and compliance will be promoted.
The key points are as follows:
- Simplified Ingredient Inclusion Procedure (Article 14a)
A new article, 14a, introduces a clear process for adding colourants, preservatives and UV filters to Annexes IV – Vi. The SCCS (Scientific Committee on Consumer Safety) will assess safety within 12 months of a request.
- Clarification on the Rules for CMR Substances
Carcinogenic, Mutagenic or Reprotoxic (CMR) remain banned unless a derogation is granted. An application for derogation for Category 1A and IB must be submitted within 3 months of classification and justified by lack of suitable alternatives and an SCCS safety evaluation. The conditions for derogations are clarified and simplified, removing the compliance with food safety, as it is deemed that food and cosmetics are fundamentally different.
The route of exposure will be taken into account: substances harmful only via the ingestion/oral route, such as sprays or lipsticks will still be banned.
- Natural Complex Substances
If a natural extract, for example an essential oil, has a CMR constituent then the whole substance is not automatically banned. The extract will only be banned if the whole substance is a CMR. If concerns arise, then the Commission may request an SCCS safety assessment.
- Nanomaterials Notification (Article 16)
The current requirement for pre-notification will be abolished. Instead, relevant data must be included in the Cosmetic Product Safety Report.
- Marketing Surveillance Reporting (Article 22)
Member State will no longer be required to submit periodic surveillance reports as the existing tools such as ICSMS and PEMSAC are deemed sufficient.
- Ingredient Glossary (Article 33)
There will no longer be a requirement for the Commission to publish a glossary of ingredient names. Instead, internationally recognised nomenclature can be used for labelling.
- Criteria for Suitable Alternatives
Suitable alternatives should provide similar function/efficacy, reduce overall risk to health/environment and be technically feasible and economically viable. They should be available at scale and not restricted by patents or supply issues. Reformulation costs and production impact should also be considered.
- Exposure Based Assessment
The current requirement for known exposure in product categories is merged into the SCCS safety assessment, avoiding duplication.
- Transitional Periods
Products that contain banned or restricted substances
- Can be placed on the market for 12 months
- Can be made available for 24 months after the ban takes effect.
Chemical Industry Action Plan
Alongside the simplification package, the European Commission presented an Action Plan for the Chemicals Industry to strengthen the competitiveness and modernisation of the EU chemical sector. The Action Plan addresses key challenges, namely high energy costs, unfair global competition, and weak demand, while promoting investment in innovation and sustainability. The full version of the Action Plan is published here.
Among the proposed measures, a few highlights are:
- Establish a Critical Chemical Alliance and offer policy support to critical production sites.
- Fiscal incentives and tax measures to boost demand for clean chemicals, sustainability, resource efficiency, and chemicals recycling among other things.
- Continued action on phasing out and minimising Per- and polyfluoroalkyl substances (PFAS) emissions through a robust, science-based restriction, while allowing use in critical applications under strict conditions where no alternatives are available.
The EU Commission will also launch EU Innovation and Substitution Hubs and mobilise EU funding under Horizon Europe (2025–2027) to accelerate the development of safer, more sustainable chemical substitutes.
Published September 26th, 2025
Article and image were generated with the assistance of Artificial Intelligence.