European Union
EU Draft Would Transfer Existing Hazard Findings Into CLP Classifications
An EU draft would transfer existing endocrine-disruptor and persistence findings into CLP harmonised classifications. Its annex entered the official repository on 20 October; no calendar application date is fixed.
Dr Steven Brennan
2 min readAI-drafted, expert reviewed
An EU draft delegated regulation would transfer existing substance hazard identifications into harmonised classifications under the Classification, Labelling and Packaging (CLP) Regulation. Its annex record was created in the official CIRCABC repository on 20 October 2026.
That date records repository availability. The act remains a draft and does not establish adopted classifications.
How Earlier CLP Changes Led To This Draft
New CLP hazard classes entered into force on 20 April 2023 under Delegated Regulation (EU) 2023/707. These included endocrine disruption for human health and the environment, and persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) properties. The regulation introduced classification criteria and related requirements. It did not itself add substance-specific harmonised entries to Annex VI, Part 3.
The 2024 CLP revision inserted Article 37(7). Subject to specified conditions, this provides a route to transfer existing endocrine-disruptor and PBT/vPvB identifications under REACH, plant-protection and biocidal-product legislation into harmonised CLP entries. The October 2026 draft uses existing assessments of those properties to avoid duplicate work.
The draft’s recitals cite earlier ECHA decisions. These include decisions of 20 June 2018 concerning the siloxanes D4, D5 and D6, and a decision of 10 October 2024 concerning triphenyl phosphate.
Existing Assessments Would Be Transferred
The draft act relies on CLP Article 37(7)(b). It would carry hazard identifications made under REACH, plant-protection and biocidal-product legislation into Annex VI, Part 3, Table 3.
These include endocrine-disrupting properties and persistent, bioaccumulative and toxic properties, or very persistent and very bioaccumulative properties. The memorandum explains that the transfer uses existing scientific assessments to avoid duplicate work.
The annex proposes triphenyl phosphate as an environmental endocrine disruptor in category 1, with hazard statement EUH430.
No Fixed Calendar Application Date
The memorandum describes an 18-month adaptation period. Article 2 contains the bracketed application-date placeholder “[first day of the month of entry into force plus 19 months]”. Entry into force would be 20 days after publication in the Official Journal.
The draft also permits voluntary early classification, labelling and packaging from entry into force. It supplies no fixed calendar application date.
Questions about this change
Does the EU Transfer ATP draft already impose new CLP classifications?
No. The act and annex remain draft documents. They propose transferring existing hazard identifications under REACH, plant-protection and biocidal-product legislation into CLP Annex VI. Their repository availability does not establish adoption.
Is there a fixed application date for the EU CLP Transfer ATP draft?
No. Article 2 contains a relative application formula tied to entry into force, and the explanatory memorandum describes an 18-month adaptation period. The draft does not establish a calendar application date.
Dr Steven Brennan
CEO and co-founder of Foresight, and a co-opted member of ECHA's Committee for Socio-economic Analysis. He holds a PhD in chemical engineering.
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