ATP 22 CLP: A reminder ahead of the May 1, 2026 deadline

Commission Delegated Regulation (EU) 2024/2564 of June 19, 2024 introduces the 22nd adaptation to technical progress of the CLP Regulation. The text was published in the Official Journal of the EU on September 30, 2024, and entered into force on the twentieth day after publication.

Mandatory application began on May 1, 2026.

Voluntary application was allowed from the date of entry into force. For anyone who follows the regulatory calendar, this was dealt with long ago. This article is an overview for those who want to check whether the changes affect them.

What the regulation covers

The regulation amends Annex VI to Regulation (EC) No 1272/2008 in three ways. It introduces new entries for substances that previously had no harmonized classification. It replaces existing entries for substances whose classification has changed. And it deletes entries that are covered by new, generic entries.

In total, it addresses the ECHA RAC opinions adopted between March and December 2022. The number of substances affected is significant. Below are the most important ones for industry at large.

The most important amended entries

This group of substances already had a harmonized classification in previous ATPs, but ATP 22 changes it.

Formaldehyde (50-00-0)

The entry for formaldehyde has been replaced by an entry that includes Carc. 1B (H350), Muta. 2 (H341), Acute Tox. 2 inhalation (H330), Acute Tox. 4 oral (H302), Skin Corr. 1B (H314) and Skin Sens. 1A (H317), plus EUH071.

Formaldehyde is present in a huge number of industrial processes and formulations: adhesives, coatings, textiles, preservation. The SDSs for every product containing formaldehyde need to be checked against this entry.

n-Hexane (110-54-3)

The entry for n-hexane has been supplemented with the classification Repr. 2 (H361f) in addition to the existing STOT RE 1 (H372, nervous system). Aquatic Chronic 2 (H411) has also been added.

n-Hexane is used as a solvent in the rubber industry, printing, footwear and extraction. Adding suspected reproductive toxicity changes the configuration of pictograms and hazard statements on labels.

Peracetic acid (79-21-0)

The entry for peracetic acid has been considerably strengthened. ATP 22 classifies this substance as Org. Perox. D (H242), Acute Tox. 2 for all three relevant routes of exposure (inhalation (H330), dermal (H310), oral (H301)), Skin Corr. 1A (H314) and Aquatic Acute 1 and Aquatic Chronic 1 (H400/H410) with M-factors of 10 and 100 respectively.

Peracetic acid is used as a biocidal active substance for disinfection in the food industry, medicine and water treatment. This is a change with a direct impact on SDSs and safety protocols.

Glyphosate (1071-83-6)

The entry for glyphosate has been supplemented with Eye Dam. 1 (H318) and Aquatic Chronic 2 (H411).

Glyphosate is one of the most widespread active substances in herbicides. Companies that formulate or distribute plant protection products containing glyphosate should check whether these added classifications change the classification of their formulations.

Benzoyl peroxide (94-36-0)

The classification of benzoyl peroxide has been changed to Org. Perox. B (H241), which means a higher degree of explosion hazard than the previous entry. Aquatic Acute 1 and Aquatic Chronic 1 (H400/H410) (M=10/M=10) have been added.

Benzoyl peroxide is used in rubber vulcanization, polymerization and as an initiator in the plastics industry.

Biphenyl-2-ol (2-phenylphenol) (90-43-7)

This biocide and preservative, also known as OPP, has received a considerably broader classification: Carc. 2 (H351), Skin Corr. 1 (H314), Eye Dam. 1 (H318), Skin Sens. 1B (H317) and Aquatic Acute 1 and Aquatic Chronic 1 (H400/H410) (M=1/M=1).

Biphenyl-2-ol is used in preservatives for paints, adhesives, paper and as a fruit washing agent.

Sulphur (7704-34-9)

Elemental sulphur receives the classification Skin Irrit. 2 (H315). The previous entry did not include this classification.

Industries that use sulphur in various forms should update their SDSs for this component.

The most important new entries

This group of substances previously had no harmonized classification at EU level. ATP 22 introduces it for the first time.

Multi-walled carbon nanotubes (MWCNTs)

The new entry for multi-walled carbon nanotubes with a geometric diameter of ≥ 30 nm to < 3 μm, a length of ≥ 5 μm and an aspect ratio of > 3:1 includes Carc. 1B (H350i) and STOT RE 1 (H372, lungs, by inhalation). The limit values for mixtures are 1% for STOT RE 1 and 0.1% for STOT RE 2. This is a new harmonized classification for materials that until now relied on self-classification.

Silver by particle size (7440-22-4)

ATP 22 introduces three separate entries for silver. The distinction is by particle size and has a direct impact on the M-factors for aquatic toxicity.

Silver, massive (diameter ≥ 1 mm): Repr. 2 (H361f) and STOT RE 2 (H373, nervous system). No hazard to the aquatic environment.

Silver powder (diameter > 100 nm and < 1 mm): the same health classifications, plus Aquatic Acute 1 (H400) and Aquatic Chronic 1 (H410) with M = 10 for both categories.

Nano silver (diameter > 1 nm and ≤ 100 nm): the same health classifications, Aquatic Acute 1 and Aquatic Chronic 1 with M = 1000 for both categories.

The hundredfold difference in M-factor between silver powder and nano silver is not negligible. Companies that use silver in formulations must know exactly which form they use.

Copper by specific surface area (7440-50-8)

A new generic entry has been introduced for copper with a specific surface area > 0.67 mm²/mg: Aquatic Acute 1 (H400) and Aquatic Chronic 1 (H410), M = 10 for both categories. At the same time, the old entry for granulated copper, which is covered by this generic entry, has been deleted. The entry for copper flakes coated with aliphatic acid has been amended to align with it.

Acetone oxime (127-06-0)

The new entry introduces Carc. 1B (H350) for acetone oxime, along with Acute Tox. 4 dermal (H312), STOT SE 3 (H336), STOT RE 2 (H373, blood system), Eye Dam. 1 (H318) and Skin Sens. 1 (H317).

Acetone oxime is used as an antioxidant and anti-skinning agent in paints and varnishes.

Benzotriazoles (95-14-7/29385-43-1)

1H-benzotriazole and methyl-1H-benzotriazole receive Aquatic Chronic 2 (H411) as new harmonized classifications.

Benzotriazoles are used as corrosion inhibitors and UV stabilizers in various industrial applications.

Sodium perborates (several entries under Index number 005-022-00-4)

The old entries for sodium perborate (six index numbers from 005-017-00-7 to 005-019-01-5) have been deleted and replaced by three new consolidated entries. The new entries carry Repr. 1B (H360FD) as the prominent classification, along with Ox. Sol. 3 or 2 depending on the form, Acute Tox. and Eye Dam. 1.

Sodium perborate is present in detergent and bleaching formulations.

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An overview for Serbian companies

Regulation (EU) 2024/2564 is an EU regulation and is not directly applicable to the Serbian market. Part of these changes has been implemented in Serbia with the amendment of the SKS list (Serbia’s national chemical classification list) in the Official Gazette of RS 88/2025.

For companies that export to the EU: from May 1, 2026, your SDSs and labels for the EU market must comply with ATP 22. Check whether your formulations contain any of the affected substances and whether a change in the classification of a component changes the classification of the final product under the summation rules of Annex I of the CLP Regulation.

For the domestic market: follow the amendments to the Serbian rulebook on SKS.

References:

• Regulation 2024/2564 - ATP22