The European Chemicals Agency (ECHA) has announced the launch, in 2026, of a coordinated enforcement action at EU level focusing on the classification, labelling and packaging of hazardous mixtures, as part of the REF-14 project. This initiative forms part of the European programme aimed at strengthening the enforcement of chemicals legislation and confirms the central role of the CLP Regulation in the placing on the market of chemicals and consumer products.
The scope of these inspections will focus on hazardous mixtures incorporated into finished products that are widely available to consumers. Particular attention will be paid to products known to contain substances or mixtures presenting risks to human health or the environment, such as certain nicotine-containing products, aerosols or air fresheners. Enforcement authorities will assess the correctness of classifications, the consistency of labelling and the adequacy of packaging, notably in light of the requirements intended to protect end users.
The CLP Regulation is based on a core principle whereby responsibility for classification lies with the supplier placing the substance or mixture on the market. This classification forms the basis of all downstream regulatory obligations, including labelling requirements, the content of safety data sheets and information duties throughout the supply chain. In practice, inspections frequently reveal classifications that have become outdated following regulatory or scientific developments, errors in the assessment of mixture hazards, or inconsistencies between the chosen classification and the associated regulatory documentation.
The REF-14 action is not limited to a purely formal assessment of compliance with the CLP Regulation. ECHA has indicated that national enforcement authorities may also verify compliance with restrictions laid down under the REACH Regulation, as well as with requirements arising from the Regulation on persistent organic pollutants. This cross-cutting approach significantly broadens the scope of inspections and increases legal risk for operators whose products present regulatory weaknesses, including where such weaknesses are not immediately apparent from labelling alone.
The consequences of non-compliance identified during an inspection may be substantial. They may include orders to bring products into compliance, product withdrawals or recalls, administrative or criminal penalties under applicable national laws, as well as logistical or customs disruptions and reputational harm for the companies concerned. In this context, CLP classification should not be viewed as an isolated formal obligation, but rather as a structuring element of compliance strategies and regulatory risk management.
Although the REF-14 campaign is scheduled for 2026, its announcement encourages economic operators to anticipate these inspections at an early stage. A critical review of existing classifications, verification of consistency between classification, labelling and safety data sheets, and assessment of the impact of recent regulatory developments are key measures to secure market access for products. This coordinated action once again highlights the central role of chemicals legislation in regulating the internal market and the heightened responsibility borne by economic operators.