Amid an evolving regulatory landscape this year, OSHA has held its share of time in the spotlight and headlines. The employee safety regulation created in 1970 now faces a potential shift toward deregulation, reduced inspections and a greater emphasis on state-level programs and voluntary compliance.
There have even been legislative efforts to abolish or “nullify” OSHA entirely, although experts believe that outcome is unlikely. Meanwhile, ongoing challenges such as understaffing, budget constraints and new potential rules for hazardous occupations are shaping the agency’s outlook.
At the same time, EHS professionals are also navigating major shifts in other long-standing chemical regulations.
For example, California Proposition 65, known as the Safe Drinking Water and Toxic Enforcement Act of 1986 was recently updated to require short-form warnings to include at least one chemical name for consumer products, making explicit that short-form warnings may be used to to provide warning for food products, and providing new tailored warnings for passenger or off-highway motor vehicle parts and recreational marine vessel parts.
Safety professionals are also responding to updates to the UN’s Globally Harmonized System (GHS) for Classification and Labelling of Chemicals. Revision 11, for instance, introduces new or revised guidance for desensitized explosives, aerosols, flammable gases and gases under pressure. These changes are intended to improve global consistency and better align with transport regulations and ISO standards.
Changes to CLP
One of the most consequential regulatory shifts of the year is the European Commission’s adoption of Amendment (EU) 2024/2865 to the Classification, Labelling and Packaging (CLP) regulation. CLP implements GHS for classifying and labeling hazardous chemicals. This update represents one of the most far-reaching changes in years.
The amendment touches nearly every facet of chemical compliance, from classification methods and labeling practices to digital communication requirements and poison center notifications (PCNs).
In total, the amendment revises 36 articles and four annexes, forcing organizations to prepare for broad operational adjustments ahead of the 2026–2027 implementation dates.
Key implementation dates include:
- July 1, 2026 — changes related to supplier identification on labels, More Than One Constituent Substances (MOCS) provisions, digital labeling provisions (if implemented), updates tied to refill stations and several labeling changes
- Jan. 1, 2027 — new label font-size requirements and PCN-related updates. Regarding the new label font size requirements there are two proposals in progress that may either postpone the implementation date until Jan. 1, 2028 [ COM/2025/526] or remove the requirements all together [COM(2025)531].
While some updates are relatively minor clarifications, others will require EHS and product stewardship teams to review and redesign internal processes, data documentation and product labels to maintain compliance.
Below is a high-level overview of some of the most relevant changes to CLP. A full breakdown can be found in the recent Sphera webinar Complying with the new CLP regulations: What you need to know.
Updated MOCS requirements
The 2024/2865 amendment clarifies expectations for classifying substances with more than one constituent including UVCBs. The clarifications make clear that constituents, impurities and additives are to be considered when classifying substances. Constituent-level data cannot be overridden by substance-level data for major hazard classes.
When classifying substances with a composition for CMRs endocrine disruptors and PBT, vPvB, PMT and vPvM constituent-level data must be considered unless substance data reveals a hazard not identified at the constituent level.
Transition to digital labels
The amendment allows digital labels as long as they meet strict technical requirements. Labels must be searchable and accessible without a login and must be reachable within two clicks. They must also be compatible across major browsers and operating systems and remain available for at least 10 years.
The content must be accessible for vulnerable groups and viewable without registration, passwords or paid access. While providing digital labels is voluntary, the physical label remains mandatory.
Evolving PCN requirements
CLP revisions include several changes to PCN obligations. Member states may now appoint the European Chemicals Agency (ECHA) as the PCN recipient. In certain situations distributors have new obligations when rebranding, relabeling or distributing mixtures.
PCNs must also now be updated when there are any changes “relevant for emergency health response.”
New labeling and font-size requirements
The CLP amendment introduces several new rules affecting label layout, readability, font size and certain exemptions. Content updates include expanded ingredient disclosures to account for new hazard classes.
Font sizes must now be proportional to the label size and the requirements are stricter and more explicit than in previous versions of CLP. For example:
- Labels must use a single font without serifs
- Line spacing must be at least 120% of the font size
- Letter spacing must support legibility
Resources and assistance
These are just some of the changes associated with CLP amendment 2024/2865 introduced to improve clarity, enforceability and communication across the chemical supply chain. Combined with shifting OSHA priorities, Prop 65 updates and changes in GHS implementation, chemical companies must prepare for a multi-layered compliance environment.
To prepare effectively, organizations should:
- Map all regulatory changes to internal processes
- Reassess mixture and substance classifications
- Begin redesigning label formats
- Evaluate digital labeling readiness
- Update PCN workflows
- PCN – evaluate what changes are relevant for emergency health response
- Monitor ongoing OSHA developments
Proactive planning will help ensure compliance ahead of the 2026–2027 CLP deadlines and strengthen overall chemical safety management regardless of how OSHA evolves under future administrations.
Contact Sphera for the resources and guidance needed to navigate these changes.
