24/06/2025

The revision of the CLP aimed to further improve the protection of human health and the environment, to enhance transparency, promote innovation to create space for safer alternatives and to clarify classification rules for new types of hazards, such as endocrine disruption, PBT (Persistent, Bioaccumulative and Toxic), Very Persistent and Very Bioaccumulative (vPvB), Persistent, Mobile and Toxic (PMT) and Very Persistent and Very Mobile (vPvM).

How could it affect your biostimulant products?

Well, the new hazard classes are unlikely to impact most biostimulant products, however, there are other changes, such as rules concerning online sales. These concern hazard information that must be visible before the purchase.

Digital labelling is also pushed, and certain information, such as use instructions to be accessed via QR codes (for instance). However, core hazard information must still be on the physical packaging.

Last but not least, there are updated labelling rules for small packagings.

Should you be willing to download the legally binding version, Regulation (EU) 2024/2865 (OJ Nov 2024), which entered into force in December 2024.

10/01/2025

The CLP regulation serves as a fundamental framework for assessing and communicating the hazards of substances and mixtures, as minor as they might be. It is NOT a risk assessment framework.

A purely “biological” and “natural” origin of components does not make a plant biostimulant “non hazardous” within the frame of the CLP.

Even plant biostimulants, regardless of their composition and mode of action, are subject to the CLP.

The right to place a product on the market without prior authorisation does not remove the obligation for classification and labelling according to the CLP.

Packaging: General CLP packaging and labelling standards are relevant in all EU Member States

The responsibility for the classification and labelling of a product, like a biostimulant, is with manufacturers, importers and downstream users.

Just to be clear: "Downstream users" are not consumers, nor distributors, but most biostimulant manufacturers (formulating products from raw/starting materials sourced from suppliers) would qualify as “downstream users”.

It is important because the CLP will help to define a hazard profile and this has implications on the product label and Material Safety Data Sheet (consequences on, for instance, transport regulations). As a product is also considered a "mixture", the CLP also applies to biostimulants and fertilisers.

Mind you: it could well be that your product will not be "classified according to the CLP", but that finding is not based on guess-work or intuition, but on an assessment based on the composition and hazard properties of the ingredients of the mixture!