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CLP ATP 22 Changes: Annex VI Updates May 2026

CLP 22nd ATP (Delegated Regulation 2024/2564): 27 new harmonised classifications added to Annex VI. Mandatory from May 1, 2026. Affected substances and impact.

·GHS Pictograms Editorial

The 22nd Adaptation to Technical Progress to the EU CLP Regulation — Commission Delegated Regulation (EU) 2024/2564 — became mandatory on May 1, 2026. As of this writing, the deadline is eight days in the past. Suppliers placing substances and mixtures on the EU market must now apply the 27 new harmonised classifications, the 16 modifications to existing entries, and the seven deletions that the 22nd ATP introduced to Annex VI of the CLP Regulation (1272/2008). Voluntary application was permitted from October 20, 2024 onward; the mandatory date is now passed.

This guide explains every substantive change CLP ATP 22 makes, names the most consequential new harmonised classifications — including multi-walled carbon nanotubes (MWCNTs), nano-form silver, and several reproductive toxicants commonly used in fragrances — and walks through what compliance teams need to verify to confirm their products are correctly classified as of May 1, 2026. We also cover the cascade effect into the EU Cosmetics Regulation, which absorbs ATP 22 classifications via Omnibus VIII (Regulation (EU) 2026/78), published in January 2026 with the same May 1, 2026 application date.

At a glance

  • Document: Commission Delegated Regulation (EU) 2024/2564 — the 22nd Adaptation to Technical Progress to CLP
  • Adopted: June 19, 2024
  • Published in OJ: September 30, 2024
  • Entered into force: October 20, 2024
  • Mandatory application: May 1, 2026 — eight days past as of this writing
  • Voluntary application: October 20, 2024 to April 30, 2026
  • Scope of changes: Annex VI, Part 3, Table 3 of CLP Regulation (1272/2008)
  • Numbers: 27 new harmonised classifications · 16 modifications · 7 deletions
  • Cascade: Omnibus VIII (Regulation (EU) 2026/78) — same May 1, 2026 deadline for EU Cosmetics Regulation alignment
  • Related tools: Label Constructor · ATE Calculator

Table of Contents

  1. What is CLP and an ATP?
  2. Timeline: how ATP 22 came into force
  3. The numbers: 27 new, 16 modified, 7 deleted
  4. Notable additions in ATP 22
  5. Cascade effect: Omnibus VIII for cosmetics
  6. Practical compliance checklist
  7. Frequently Asked Questions

What is CLP and an ATP?

The CLP Regulation — Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of substances and mixtures — is the EU implementation of the United Nations Globally Harmonized System (UN GHS). It entered into force on January 20, 2009 and applies directly across all 27 EU Member States, plus Iceland, Liechtenstein, and Norway through the European Economic Area Agreement. The CLP Regulation requires manufacturers, importers, and downstream users to classify, label, and package hazardous substances and mixtures consistently before placing them on the EU market.

Annex VI of the CLP Regulation lists the substances for which the European Union maintains a harmonised classification and labelling. A harmonised classification, sometimes called a CLH entry, is binding on all suppliers — manufacturers cannot deviate from the agreed classification for those substances, even if they hold private data suggesting otherwise. Suppliers may add hazard categories beyond the harmonised entry if their data justifies it, but they cannot remove or weaken any harmonised category.

The European Commission updates Annex VI through Adaptations to Technical Progress (ATPs) — typically one per year. Each ATP is published as a Commission Delegated Regulation amending Table 3 of Part 3 of Annex VI. Companies need to monitor each ATP because new harmonised classifications can require label updates, SDS revisions, mixture reclassification, and downstream notification (CLP Notification, UFI/PCN). The 21st ATP applies from September 1, 2025; the 22nd ATP from May 1, 2026; the 23rd ATP from February 1, 2027. The cadence is rapid.

For a wider view of how the EU CLP Regulation aligns with UN GHS revisions, see our country-by-country UN GHS implementation map and our UN GHS Rev 11 changes guide, which covers the underlying UN-level revisions that flow into CLP through ATPs over time.

Timeline: how ATP 22 came into force

The 22nd ATP follows the standard CLP delegated act lifecycle. The European Commission, advised by the ECHA Risk Assessment Committee (RAC) and the Committee for Socio-economic Analysis (SEAC), drafts the proposed amendment. After the draft passes through Council and Parliament scrutiny, the Commission adopts the delegated act, publishes it in the Official Journal, and sets a transition period before mandatory application.

DateMilestone
June 19, 2024Commission adopts Delegated Regulation (EU) 2024/2564
September 30, 2024Published in the Official Journal of the European Union
October 20, 2024Regulation enters into force (20 days after OJ publication)
October 20, 2024 to April 30, 2026Voluntary application period — suppliers may apply early
May 1, 2026Mandatory application — all suppliers must comply

The 19-month voluntary application period is typical for a CLP ATP. It gives suppliers time to commission additional testing, update SDS authoring tools, refresh labels, and notify downstream customers. Suppliers who chose voluntary early adoption have been operating under ATP 22 classifications since late 2024; those who waited for the mandatory date have eight days behind them as of this writing.

The numbers: 27 new, 16 modified, 7 deleted

Across Table 3 of Part 3 of Annex VI, ATP 22 makes 50 substantive entries:

  • 27 new harmonised classifications added for substances or substance groups that did not previously appear in Annex VI.
  • 16 modifications to existing harmonised entries, typically tightening hazard categories, adding new hazards, or refining concentration limits and M-factors.
  • 7 deletions removing entries that no longer warrant a harmonised classification — usually because the underlying scientific evidence has been re-evaluated or because the substance has been superseded by a more specific entry.

This makes ATP 22 a medium-sized ATP. The 21st ATP (Delegated Regulation (EU) 2024/197), which applied from September 1, 2025, added 32 new entries; the 18th ATP added 39. ATP 22’s 27 additions sit close to the historical median.

The new and modified entries cluster across several hazard areas: carcinogenicity (Carc. 1B for several novel materials), specific target organ toxicity from repeated exposure (STOT RE 1 and 2 for inhalation routes), reproductive toxicity (Repr. 1B and 2 for several fragrance and cosmetic ingredients), and environmental hazards (Aquatic Acute 1, Aquatic Chronic 1 for several metals in nano-particle form). Several entries involve nano-form distinctions — meaning the macroscopic form of a substance carries one classification, while the nano form carries a different, often stricter, classification.

The full lists of new, modified, and deleted entries are available on the ECHA Annex VI to CLP page, where the agency publishes a non-binding consolidated Excel table for ease of use. The legally binding text is the Official Journal version of Delegated Regulation (EU) 2024/2564 itself.

Notable additions in ATP 22

Five additions deserve specific attention because they affect either widely used industrial materials or high-volume consumer product ingredients.

Multi-walled carbon nanotubes (MWCNTs)

MWCNTs with a geometric tube diameter range from 30 nm to under 3 µm, length of 5 µm or greater, and aspect ratio greater than 3:1 receive a harmonised classification of Carcinogenicity Category 1B (H350i — May cause cancer by inhalation), Specific Target Organ Toxicity, Repeated Exposure Category 1 for the lungs (H372 — Causes damage to lungs through prolonged or repeated exposure by inhalation), with the GHS08 health hazard pictogram and the signal word “Danger”.

The classification applies generic concentration limits: STOT RE 1 (H372) at concentrations greater than or equal to 1%, and STOT RE 2 (H373) at concentrations between 0.1% and 1%. This affects manufacturers of nanocomposites, lithium-ion battery anodes, conductive polymers, and specialty composites. Mixture classification calculations need to account for these limits — our ATE Calculator handles the GHS Rev 7 acute toxicity arithmetic, though MWCNT classification primarily concerns repeated exposure (STOT RE) rather than acute toxicity.

Silver nano-particles (CAS 7440-22-4)

Silver in nano form — defined as particle diameter greater than 1 nm and less than or equal to 100 nm — receives a harmonised classification of Reproductive Toxicity Category 2 (H361f — Suspected of damaging fertility), STOT RE 2 for the nervous system (H373), Aquatic Acute 1 (H400), and Aquatic Chronic 1 (H410). The classification carries pictograms GHS08 and GHS09, with signal word “Warning”.

The granulometric distinction is important: bulk silver does not carry the same harmonised classification, and silver in some other particle size ranges may have different entries. The ATP 22 classification specifically targets the nanoparticle range that is increasingly used in antimicrobial coatings, electronics conductive inks, medical devices, and consumer textiles. Suppliers of nano silver must update SDSs and labels by May 1, 2026.

Hexyl salicylate (CAS 6259-76-3)

Hexyl salicylate is a fragrance and cosmetic ingredient widely used in perfumery, laundry detergents, fabric softeners, air fresheners, and personal care products. ATP 22 introduces a harmonised classification reflecting the SCCS (Scientific Committee on Consumer Safety) opinion on its effects. The classification flows into the EU Cosmetics Regulation through Omnibus VIII (covered in the next section), changing how this ingredient may be used in cosmetic formulations.

Other fragrance and cosmetic substances

Several other ingredients of interest to the fragrance and cleaning product industries appear in the ATP 22 additions, including α-methyl-1,3-benzodioxole-5-propionaldehyde (CAS 1205-17-0) and 2,4-dimethylcyclohex-3-ene-1-carbaldehyde (CAS 68039-49-6). These additions reflect the ongoing review of fragrance materials by ECHA’s Committee for Risk Assessment in response to dossiers submitted by Member States and industry associations.

Reproductive toxicants

ATP 22 includes several substances classified as Repr. 1B (presumed human reproductive toxicants) — a designation that triggers significant downstream consequences, including potential SVHC listing and restriction discussions. Suppliers handling these substances should review CMR substance management procedures, including stricter exposure controls, mandatory health surveillance for workers, and consumer product restrictions where relevant.

For label updates triggered by the new harmonised classifications, our GHS Label Constructor generates fully compliant labels at all five CLP volume tiers with correct pictogram sizing.

Cascade effect: Omnibus VIII for cosmetics

A CLP harmonised classification does not stay confined to chemicals manufacturing. EU sectoral regulations — for cosmetics, toys, food contact materials, biocides, and others — pull through CLP classifications automatically, often with the same application date.

For ATP 22, the most direct cascade is into the EU Cosmetics Regulation (EC) No 1223/2009. Regulation (EU) 2026/78 — informally known as Omnibus VIII — was published on January 13, 2026 and updates the Cosmetics Regulation Annexes II (prohibited substances) and III (restricted substances) to incorporate the ATP 22 harmonised classifications relevant to cosmetic use.

Two notable changes:

  • Hexyl salicylate receives new restrictions in cosmetic products following the SCCS opinion underpinning the ATP 22 entry. Concentration limits and product-category restrictions tighten.
  • Silver in nano form receives differentiated treatment depending on particle size (granulometry). The toxicological risk profile changes substantially with particle size, and the cosmetics regulation now reflects this directly.

Omnibus VIII has the same May 1, 2026 application date as the underlying ATP 22. Cosmetic product manufacturers cannot place non-compliant products on the EU market after that date, and existing stock placed before that date is subject to phase-out arrangements specific to each ingredient.

The sectoral cascade pattern is worth understanding. CLP harmonised classifications are the upstream trigger; sectoral regulations are the downstream amplifier. A single ATP can therefore reshape multiple regulatory regimes within the same compliance cycle.

Practical compliance checklist

For suppliers reviewing their position eight days after the mandatory deadline, the practical workflow is:

Confirm classification updates. Pull your current Annex VI-aligned substance classifications and cross-check against the ATP 22 list. ECHA’s non-binding Excel table is the fastest reference; the legally binding text is Delegated Regulation (EU) 2024/2564 itself. Any substance you handle that appears in the ATP 22 additions or modifications needs a verified, dated update record.

Verify SDS revisions are deployed. Section 2 (Hazard identification), Section 3 (Composition), Section 9 (Physical and chemical properties), and Section 15 (Regulatory information) are the most likely SDS sections to need updates. The SDS revision date should be on or before May 1, 2026 for any product affected by ATP 22.

Audit label artwork. Containers placed on the EU market after May 1, 2026 must carry labels reflecting the new harmonised classifications. If your product affected by ATP 22 still carries pre-ATP 22 label stock, that stock cannot be placed on the market — it must be relabelled or destroyed. Pre-ATP 22 stock that was already placed on the market before May 1, 2026 is generally allowed to remain in distribution under transitional rules, but downstream customers may push for early relabelling.

Update CLP Notifications and UFI/PCN entries. Any change in classification triggers an update obligation under Article 45 (Poison Centre Notifications) for mixtures classified for health or physical hazards. The notification timeline is generally tied to the classification change date, not a separate ATP 22 deadline.

Review mixture classifications. Mixture classification under CLP Annex I (Part 3) cascades from substance classifications. If a substance in your mixture has had its classification tightened by ATP 22, your mixture may need recalculation — particularly for STOT RE entries with low generic concentration limits. Bridging principles (CLP Annex I, Section 1.1.3) may apply.

Document the changeover. Keep a record of when each affected SDS was reissued, when label stock was updated, and when downstream customers were notified. ECHA enforcement projects routinely audit ATP transitions; documentation prevents ambiguity.

Monitor ATP 23. Delegated Regulation (EU) 2025/1222 — the 23rd ATP — applies from February 1, 2027. The transition window is shorter than for ATP 22. Add it to your compliance calendar now.

Frequently Asked Questions

What is CLP ATP?

ATP stands for Adaptation to Technical Progress. In the context of the EU CLP Regulation, an ATP is a Commission Delegated Regulation that amends Annex VI of CLP — specifically Table 3 of Part 3 — to update the list of substances with harmonised classification and labelling. ATPs are typically published once or twice per year, after the European Chemicals Agency’s Committee for Risk Assessment (RAC) issues opinions on individual substance dossiers. The ATP 22 we cover here is the 22nd such adaptation since CLP entered into force.

When does CLP ATP 22 apply?

The 22nd ATP — Commission Delegated Regulation (EU) 2024/2564 — entered into force on October 20, 2024 and became mandatorily applicable on May 1, 2026. From October 20, 2024 to April 30, 2026, suppliers could voluntarily apply the new classifications. From May 1, 2026 onward, all suppliers placing affected substances and mixtures on the EU market must comply with the updated harmonised classifications.

What is harmonised classification under CLP?

A harmonised classification is a hazard classification for a specific substance that is binding across the EU. Suppliers cannot deviate from a harmonised classification — they cannot weaken or remove any hazard category. Harmonised entries are listed in Annex VI, Part 3, Table 3 of the CLP Regulation. Substances not in Annex VI must be self-classified by the supplier based on available data. Suppliers may add additional hazard categories to a harmonised entry if their own data justifies it, but they cannot reduce the harmonised classification.

Which substances are added in CLP ATP 22?

ATP 22 adds 27 new harmonised classifications, modifies 16 existing entries, and deletes 7 entries. Notable additions include multi-walled carbon nanotubes (MWCNTs) classified as Carc. 1B, silver in nano form classified as Repr. 2 with multiple environmental and STOT RE hazards, hexyl salicylate (a common fragrance ingredient), α-methyl-1,3-benzodioxole-5-propionaldehyde, and 2,4-dimethylcyclohex-3-ene-1-carbaldehyde. The full list is available in Delegated Regulation (EU) 2024/2564 and ECHA’s non-binding consolidated Excel table.

Does CLP ATP 22 affect cosmetics?

Yes. The EU Cosmetics Regulation (EC) No 1223/2009 was updated through Regulation (EU) 2026/78 — Omnibus VIII — published on January 13, 2026 with the same May 1, 2026 application date. Omnibus VIII incorporates the ATP 22 classifications relevant to cosmetic use into Annexes II and III of the Cosmetics Regulation. Hexyl salicylate and nano silver are the most consequential changes for cosmetic formulators.

Key takeaways

  • CLP ATP 22 became mandatory on May 1, 2026. As of this writing, the deadline is eight days in the past.
  • 27 new harmonised classifications, 16 modifications, 7 deletions are added to Annex VI of the CLP Regulation by Delegated Regulation (EU) 2024/2564.
  • Notable additions include multi-walled carbon nanotubes, nano silver, hexyl salicylate, and several fragrance ingredients with reproductive toxicity classifications.
  • Cascade into cosmetics: Omnibus VIII (Regulation (EU) 2026/78) updates the EU Cosmetics Regulation with the same May 1, 2026 deadline.
  • Compliance verification is the practical task now — confirming SDS updates, label artwork, mixture reclassification, and downstream notifications are in place.
  • ATP 23 looms: Delegated Regulation (EU) 2025/1222 applies from February 1, 2027.

Sources

  1. Commission Delegated Regulation (EU) 2024/2564 of 19 June 2024 amending Regulation (EC) No 1272/2008 of the European Parliament and of the Council as regards harmonised classification and labelling of certain substances. Published in OJ L on 30 September 2024. Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202402564
  2. Annex VI to CLP — Table of harmonised entries. European Chemicals Agency (ECHA). Non-binding consolidated reference. Available at: https://echa.europa.eu/information-on-chemicals/annex-vi-to-clp
  3. The 22nd ATP to CLP has been officially published. H2 Compliance, March 24, 2025. Industry analysis with substance examples.
  4. EU Publishes 22nd ATP to CLP Regulation Effective May 2026. Global Product Compliance (GPC) Gateway, November 2024. List of new harmonised classifications.
  5. EU publishes 22nd ATP to CLP Regulation. Nanotechnology Industries Association (NIA), 2024. Industry briefing on nano-form additions.
  6. Regulation (EU) 2026/78 (Omnibus VIII) of 13 January 2026 amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products. Published in the Official Journal of the European Union.
  7. CLP Legislation overview. European Chemicals Agency (ECHA). Available at: https://echa.europa.eu/regulations/clp/legislation
  8. Substance classification data referenced in this article is sourced from the GHSSymbols.com Hazards Database, derived from ECHA CLP Annex VI list of harmonised classifications, last synchronised in March 2026.