EU Regulation 2025/2439: CLP Updates for the Pet Care and Air Fragrances Sectors

Introduction

On December 3, 2025, Regulation (EU) 2025/2439 was published in the Official Journal of the European Union, substantially amending the application deadlines for Regulation (EU) 2024/2865 on the classification, labeling, and packaging (CLP) of hazardous substances and mixtures.

This regulatory update is particularly relevant for operators in the Pet Care and Air Fragrances sectors, who market products frequently subject to hazard classification due to the presence of surfactants, preservatives, allergenic fragrances, essential oils, and solvents.

Regulatory Context

Regulation (EU) 2024/2865, adopted on November 20, 2024, and entered into force on December 10, 2024, introduced significant amendments to Regulation (EC) No. 1272/2008 (CLP), with particular reference to:

• Label formatting requirements (typeface, size, spacing)

• Requirement to provide the physical address of the responsible party in the European Union

• Provisions regarding the advertising and distance selling of dangerous products

• Voluntary introduction of digital labels

• New classification criteria for substances containing multiple constituents (MOCS)

• Shortened deadlines for relabeling following classification changes

The originally planned implementation dates (July 2026 and January 2027) raised concerns among European industry, particularly among SMEs, regarding the time required for full compliance.

Changes Introduced by Regulation (EU) 2025/2439

The new regulation responds to the concerns raised by the Draghi Report on European competitiveness, recognizing the need for more appropriate implementation times to preserve the competitiveness of European businesses.

Realignment of Application Dates

Regulation 2025/2439 does not change the substantive requirements introduced by Regulation 2024/2865, but significantly postpones the application deadlines, consolidating them primarily to January 1, 2028.

Provision Original Date New Date Postponement

Label Format Requirements January 1, 2027 January 1, 2028 +12 months

Relabeling Obligations July 1, 2026 / January 1, 2027 January 1, 2028 Unified

Advertising Provisions July 1, 2026 January 1, 2028 +18 months

Distance Selling July 1, 2026 J anuary 1, 2028 +18 months

Health Response Information January 1, 2026 January 1, 2027 +12 months

Important: Regulation (EU) 2025/2439 entered into force on December 23, 2025, twenty days after its publication in the Official Journal.

Impact on the Pet Care and Air Fragrances Sectors

Sector Scope

The CLP changes particularly affect the following products:

Pet Care Sector:

• Animal hygiene products containing classified surfactants, perfumes, and preservatives

• Antiparasitic formulations (spot-ons, sprays, impregnated collars)

• Surface cleaners for animals (litter boxes, cages, aquariums)

• Sanitizing and deodorizing products for pet households

• Veterinary medicated and dermatological shampoos

Air Fragrances Sector:

• Liquid reed diffusers containing solvents and essential oils

• Scented sprays formulated with propellants and/or alcohol

• Refills for electric diffusers containing volatile fragrances

• Scented candles with fragrances that exceed allergenic thresholds

• Preparations based on pure or blended essential oils

• Gel air fresheners containing absorbent polymers and Fragrances

Label Format Requirements (Effective January 1, 2028)

The new technical formatting specifications apply to all products classified as hazardous under the CLP Regulation:

Minimum Character Size (x-height):

• Capacity ≤ 0.5 liters: characters ≥ 1.2 mm

• Capacity > 0.5 - 3 liters: characters ≥ 1.4 mm

• Capacity > 3 - 50 liters: characters ≥ 1.8 mm

• Capacity > 50 - 500 liters: characters ≥ 2.0 mm

• Capacity > 500 liters: characters ≥ 2.0 mm

Typographic Requirements:

• Minimum line spacing: 120% of character height

• Guaranteed legibility on any application surface

Identification of the Responsible Person in the EU (Effective January 1, 2028) 2028)

The label must include the full contact details of a responsible supplier established in the European Union, including:

• Name (full company name)

• Full address (street, house number, postal code, city, Member State)

• Telephone number

• Email address

Generic indications such as "Made in EU" or references to the company name alone without full contact details are no longer sufficient.

Advertising Provisions (Effective January 1, 2028)

For products classified as dangerous, all advertising must include:

• Relevant hazard pictograms

• Warnings (warning signs)

• Main hazard statements

Claim Restrictions

The use of terms that could mislead consumers into underestimating hazards is expressly prohibited, such as:

• "Non-toxic"

• "Harmless"

• "Eco-friendly"

• "Natural" (if used to suggest no danger)

• "Environmentally safe"

This provision is particularly relevant for the sectors in question, where marketing traditionally emphasizes the naturalistic and environmental sustainability aspects of products.

Distance Selling and E-commerce (Effective January 1, 2028)

Sales offers submitted before the contract is concluded (quotes, e-commerce shopping carts) must include:

• Hazard pictograms

• Relevant hazard statements

• Reference to complete safety information

This provision significantly impacts digital sales channels, which are increasingly important for both sectors.

Relevance to Typical Formulations

Example 1: Antiparasitic Shampoo for Dogs

Animal shampoos, conditioners, and cleansers containing anionic/non-ionic surfactants and allergenic fragrances frequently have classifications such as:

• H319 - Causes serious eye irritation

• H315 - Causes skin irritation

• H317 - May cause an allergic skin reaction

• H412 - Harmful to aquatic life with long-lasting effects

Scented Candles

Scented candles containing allergenic fragrances above threshold limits (typically 0.01% for skin allergens such as Limonene, Linalool, Citronellol, Geraniol) commonly have classifications such as:

• H317 - May cause an allergic skin reaction

• H411/H412 - Toxic/Harmful to aquatic life with long-lasting effects

The presence of paraffin waxes or other components may They also carry additional classifications, requiring particular attention in the formulation and labeling of these products, which are widely used in the home fragrance industry.

Diffusers and Home Fragrances

Reed diffusers containing solvents (glycols, alcohols) and essential oils, as well as scented sprays with flammable propellants, commonly have the following classifications:

• H226 - Flammable liquid and vapor

• H317 - May cause an allergic skin reaction

• H411/H412 - Toxic/Harmful to aquatic organisms

Pure Essential Oils

Most essential oils marketed in their pure form have multiple hazard classifications, including acute toxicity, skin irritation, sensitization, and aquatic hazard.

Implementation Timeline

Phase 1: 2026 - Preparatory Period

2026 represents a transition period without mandatory regulatory deadlines, to be used strategically for product portfolio audits, gap analyses, and operational planning.

Phase 2: January 1, 2027

The following will come into effect:

• Obligation to provide health information to poison control centers

• More stringent specific labeling rules (Annex IV)

Phase 3: January 1, 2028

Full implementation of all new format, addressing, advertising, and distance selling requirements.

Technical Sector Considerations

Limited Labeling Spaces

Typical formats in the Pet Care and Fragrance sectors (50-250 ml bottles, 100-150 ml diffusers) have limited labeling space. The new minimum font size and spacing requirements may require a complete redesign of the layout or the adoption of fold-out systems (booklet labels).

Compatibility with "Green" Marketing

The restriction on ecological and nature-related claims requires a substantial review of communication strategies, particularly relevant for products positioned in the premium, eco-oriented segments. It is necessary to distinguish factual information about the composition from prohibited safety claims.

Impact on Digital Channels

The requirement to display hazard information in distance selling offers requires significant technical interventions on proprietary e-commerce platforms, third-party marketplaces, and social commerce.

Conclusions

Regulation (EU) 2025/2439 offers economic operators a more favorable timeframe for implementing the updated CLP requirements, without however changing their substance. The "stop-the-clock" approach reflects the European institutions' sensitivity to the operational needs of businesses, while preserving the objectives of protecting human health and the environment.

For the Pet Care and Air Fragrances sectors, characterized by complex formulations, limited labeling space, and marketing strategies strongly oriented towards nature and environmental values, compliance requires a structured approach and specialized skills.

The unified date of January 1, 2028, represents an opportunity to implement the changes in a coordinated and efficient manner, avoiding piecemeal adjustments and optimizing the necessary investments.