Reinforced CLP enforcement in 2026: a strong signal for economic operators

As the EU prepares for a new wave of inspections in 2026, economic operators will need to be more vigilant than ever: the ECHA has announced a major coordinated action to verify the classification, labelling and packaging of hazardous mixtures. This initiative, part of the REF‑14 project, reinforces the central role of the CLP Regulation in placing chemical and consumer products on the market, signalling heightened regulatory expectations across the entire supply chain.

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 In practice, inspections frequently reveal classifications that have become outdated following regulatory or scientific developments, errors in the assessment of mixture hazards, or inconsistencies between the chosen classification and the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.

The 21st Package of European Sanctions Against Russia and Belarus: Between Judicial Protection for European Operators and the Assertion of Ever-Broader Extraterritoriality

Adopted on July 23, 2026, by the Council of the European Union, the 21st sanctions package against Russia and Belarus contains innovative and strong measures that symbolize the evolution of European sanctions law: protection for European operators against proceedings initiated in Russia, reaffirmation of the extraterritoriality of European sanctions, autonomous categories of sensitive goods and technologies subject to export controls, and the development of enhanced export controls to third countries, heavily inspired by U.S. export control regimes.

New US tariffs under Section 301 (forced labour) on European exports cannot be combined with those under the Turnberry Agreement 

Since 24 July, the United States has been applying new additional import duties, based on Section 301 of the Trade Act of 1974, to goods originating in 60 countries , which the US administration accuses of failing to ban imports of products made using forced labour or, in some cases, of failing to effectively enforce such a ban, even though it exists. For products originating in the European Union, the additional duty is calibrated to bring the cumulative rate of the most-favoured-nation duty and the new Section 301 duty to 10 per cent. The measure effectively replaces the temporary duties under Section 122 of the same Act, which were also set at 10 per cent and were due to expire on the same day.

Foreign Investment Screening: The European Union Strengthens and Harmonises Its Framework

Against a backdrop of increased scrutiny of foreign investment within the European Union, Regulation (EU) 2026/1386 replaces the framework established in 2019. While it does not create a single EU-level authorisation procedure, it further harmonises national screening mechanisms and broadens the range of transactions that may be subject to review.