CLP Revision: Why Is Industry Surprised by Something That’s Been Known for Two Years?

Surprised. Stunned. Indignant

Those were my first reactions upon reading the minutes of the “Reality Check Workshop: On the possible simplification of Chemicals legislation CLP,” organized by the European Commission. What was meant to be a working session quickly turned into a lament about the recently introduced CLP revision. But how is it possible that so many are still caught off guard?

The CLP Revision Didn’t Come Out of Nowhere

The first proposal for the CLP revision was published back in 2022. This was followed by consultations with stakeholders, public input rounds, and intense lobbying both in public and behind closed doors. The European Commission, the Parliament, the Council, and the Economic and Social Committee all reviewed and adjusted the proposal. After each round: more lobbying.

For over two years, the contents of the revision at least in broad terms have been known. Yet now, just months after the updated CLP entered into force, there’s talk of postponing deadlines and even reversing some of the changes.

Why the Surprise?

That’s the question that really puzzles me. Was our communication flawed? Did industry associations and companies truly fail to spread the word? Or did everyone simply bury their heads in the sand?

Let’s be clear: the changes introduced by the CLP revision are far-reaching, especially when it comes to labeling requirements. From product composition to packaging and supply chains everyone needs to adjust. But haven’t we had two full years to prepare? What exactly is so surprising?

Confusion Over Postponement and Rollbacks

What really shocked me was the suggestion to postpone deadlines or worse, revise the requirements again. A revision of the revision? But think about the companies that have already invested heavily. New labels, updated production lines, advanced multilayer labeling technology you can’t just throw that all aside.

Postponing deadlines might be defensible (we’ve seen this before with PCN notification delays), but rolling back the actual requirements? That would require going through the entire legislative process again which took two years the first time. By then, the current deadlines will have long passed.

A False Sense of Hope?

To me, it feels like industry is being offered false hope. The same institutions that reviewed and passed the revision will now have to re-evaluate it using largely the same information. Why would their conclusions be any different? Simply because industry now disapproves? That’s wishful thinking.

This smells of the same kind of political inconsistency we see in national policies. Mandatory heat pumps? Never mind. No more gas drilling? Actually, let’s do it. And now: sweeping changes to CLP but maybe not?

What Now?

Honestly, I don’t dare make predictions anymore. What once seemed impossible a rollback of the CLP revision now seems oddly plausible. Just six months after implementation.

Want context on the leaked proposal? Check it out here:
👉 Leaked info on LinkedIn

For now, rest assured that we’re monitoring these developments closely. You’ll be the first to know if anything changes.