Draft 24th ATP to CLP: Substances Industry Should Start Monitoring Now
- 1 day ago
- 3 min read
Updated: 17 hours ago
The draft 24th Adaptation to Technical Progress (ATP) to the CLP Regulation (EC) No 1272/2008 proposes a significant number of new harmonised classifications that could affect chemical substance portfolios across several industrial sectors. Although the proposal has not yet been formally adopted, it already provides valuable regulatory news and scientific insights that companies can use to anticipate potential impacts on their substances and products.
According to the current draft, 48 substances would receive new harmonised classifications, while 10 substances are proposed for reclassification. These updates are particularly relevant for companies involved in sectors such as coatings and adhesives, plastics and polymers, cosmetics and fragrances, and water treatment or biocides, where several of the substances included in the draft ATP are commonly used. As a result, manufacturers, importers, and downstream users may need to review the regulatory status of substances in their portfolios and assess implications for mixtures, labelling, and safety data sheets.
One of the most notable aspects of the draft ATP is the number of high-concern hazard classes proposed. The draft includes four substances classified as Carcinogenicity Category 1A or 1B (among which [ethane-1,2- diylbis[nitrilobis(methylene)]]tetrakisphosphonic acid, sodium salt , CAS n° 22036-77-7), thirty substances classified as Reproductive Toxicity Category 1A or 1B (among which bisphenol F, CAS n° 620-92-8, sodium bromide, CAS n° 7647-15-6, piperonal, CAS n° 120-57-0), and four substances classified for Specific Target Organ Toxicity following repeated exposure (STOT RE 1) (among which sodium bromide, CAS n° 7647-15-6, thymol, CAS n° 89-83-8, fosthiazate, CAS n° 98886-44-3). In addition, among the proposed reclassifications, two substances would receive a STOT RE 1 classification, one substance would be reclassified for reproductive toxicity, and another would receive a classification as a respiratory sensitiser.
It is important to emphasise that the current document is still a draft proposal, and therefore the classifications it contains are not yet final. Discussions within the CARACAL group and the remaining steps of the legislative process could still lead to modifications before the ATP is formally adopted. Once adopted, the usual ATP timeline would apply, beginning with publication in the Official Journal of the European Union, followed by entry into force approximately twenty days later, and a transition period of around 18 months.
Even at this early stage, however, the draft ATP provides valuable input for regulatory monitoring and scientific watch activities, allowing companies to anticipate upcoming regulatory changes. Organisations can start by reviewing their substance portfolios to determine whether any of the substances included in the proposal are relevant to their products or supply chains.
From there, companies should assess potential downstream impacts, such as changes to mixture classifications, labelling requirements, or safety documentation. In parallel, it is essential to continue monitoring developments, as draft ATPs may evolve before final adoption.
Understanding CLP lists: from early signals to binding classifications
Monitoring ATP updates requires understanding the different types of CLP-related lists that provide complementary regulatory information at different stages.
Draft ATPs (under consultation) provide early visibility on proposed classifications based on RAC scientific opinions and represent forward-looking regulatory intelligence.
The Registry of CLH Intentions enables early identification of substances under evaluation, supporting proactive regulatory watch.
Adopted ATPs (not yet applicable) provide a transition phase before legal enforcement, allowing companies to anticipate compliance actions.
CLP Annex VI contains legally binding harmonised classifications that must be applied by industry.
Together, these lists form a continuous regulatory monitoring framework, from early signal detection to legally binding obligations.
For many companies, keeping track of developments such as ATP updates, new classifications, and other regulatory initiatives can be challenging, particularly when managing large portfolios of substances across multiple markets. This complexity has led to increased use of regulatory monitoring tools for chemicals and substance tracking solutions.
Digital solutions can support organisations in monitoring regulatory lists, tracking toxicological updates, and identifying substances impacted by regulatory changes, enabling earlier and more informed decision-making.
The CEHTRA WATCH platform supports companies in:
tracking regulatory changes affecting their substances
monitoring toxicological data and scientific updates
identifying portfolio exposure to regulatory developments
By monitoring developments such as the draft 24th ATP and evaluating potential impacts ahead of time, companies can reduce regulatory uncertainty and ensure a smoother transition when new classifications become legally binding.
Get in touch with our experts to assess the impact of these regulatory changes on your substance portfolio.
