
EU Launches RESourceEU Action Plan to Tackle Critical Raw Materials Dependency
The EU’s RESourceEU Action Plan aims to reduce critical raw materials dependency, boost recycling and accelerate diversification for industrial resilience.


The European Union has adopted Regulation (EU) 2025/2439, introducing new transitional provisions that defer the application of several labelling and classification rules under the amended CLP Regulation (EC) No 1272/2008. Published in the Official Journal of the European Union on 3 December 2025, this amendment revises deadlines originally established by Regulation (EU) 2024/2865.
The updated regulation addresses growing concerns among industry stakeholders over the complexity, administrative load and cost implications of the revised CLP requirements. This deferral will have a broad impact across the chemicals value chain—from chemical manufacturers and distributors to online retailers and fuel suppliers—all of whom now have additional time to adjust operations and ensure compliance.
Under the new rules, multiple articles and annexes of Regulation (EU) 2024/2865 now have revised enforcement dates, offering a phased implementation schedule from 2026 to 2028.
1 July 2026:
Several provisions concerning label formatting, relabelling obligations, advertisement requirements, and rules for distance sales offers must be complied with from this date. This is one year later than originally planned.
1 January 2027:
Requirements affecting classification, labelling, and packaging of hazardous substances and mixtures, including certain updates in Annex IV, will come into effect.
1 January 2028:
Additional provisions—including those in Annex I and Annex II—pertaining to labelling content, hazard communication and reporting will apply from this date. These include more complex elements of the revised CLP framework and are intended to give operators the longest preparation window.
To support smooth transition:
These extended grace periods are designed to prevent premature relabelling, unnecessary costs and supply chain disruption.
One of the most contentious areas of Regulation (EU) 2024/2865 was its requirement for fuel labelling at filling stations. Companies were originally expected to display:
However, after feedback from industry and an internal Commission review, these measures were found to be impractical, expensive, and not contributing meaningfully to environmental or health protection.
The 2025 amendment has postponed these fuel labelling obligations pending further assessment. This allows regulators to potentially remove or simplify requirements that risked creating disproportionate compliance costs for fuel suppliers.
This legislative adjustment is part of a wider EU strategy to maintain competitiveness without undermining safety. As noted in the 2024 Draghi Report on the future of European competitiveness, overregulation threatens to limit innovation and reduce operational flexibility for European businesses.
In response, the European Commission launched proposals to simplify procedures and reduce the regulatory burden under multiple chemical regulations, including the CLP framework. The revised schedule reflects a more risk-proportionate, business-friendly approach while still upholding high standards for human health and environmental protection.
For SMEs and downstream users, this delay provides crucial breathing room to adapt systems, train staff, revise documentation and avoid potential penalties.
Regulation (EU) 2025/2439 of the European Parliament and of the Council of 26 November 2025 amending Regulation (EU) 2024/2865 as regards dates of application and transitional provisions (Text with EEA relevance)
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