New GHS CLP Rulebook 91/25: The most important changes for the chemical industry

The Rulebook on the classification, packaging, labelling and advertising of chemicals No. 91/25 (“Official Gazette of RS”, No. 91/2025) has entered into force and represents the most significant change to the chemical classification system in Serbia since 2013.

Application begins on September 1, 2026 – which means you have less than 10 months to fully align your documentation and processes.

WHAT IS REALLY NEW IN GHS CLP RULEBOOK 91/25?

1. ENDOCRINE DISRUPTORS – THE FIRST REGULATORY OBLIGATION IN SERBIA

This is the most significant novelty. For THE FIRST TIME in Serbian legislation, an obligation has been introduced to label chemicals (substances and mixtures) that can disrupt the endocrine system.

New statements – Human health (Annex 1, Part 3, Section 3.11)

EUH380: “May cause endocrine disruption in humans” (category 1)

EUH381: “Suspected of causing endocrine disruption in humans” (category 2)

New statements – Environment (Annex 1, Part 4, Section 4.2)

EUH430: “May cause endocrine disruption in the environment” (category 1)

EUH431: “Suspected of causing endocrine disruption in the environment” (category 2)

What are endocrine disruptors?

Substances that can affect the functions of the hormonal system and thereby cause adverse effects on the health of organisms or their progeny.

Which industries are affected?

Plastics manufacturing: Phthalates and other plasticisers in PVC production
Cosmetics industry: Certain UV filters, parabens
Agricultural chemicals: Pesticide components
Pharmaceutical industry: APIs (active pharmaceutical ingredients) with hormonal effects
Chemical industry: Bisphenol A (BPA) and similar compounds

What do you need to do?

Check your portfolio: Do your products contain substances identified as endocrine disruptors?
Update your SDSs: Section 2 (Hazards identification) must contain the new EUH codes; in Section 3 (Composition/information on ingredients), mark the substances in accordance with the new hazard classes
Revise your labels: Add the appropriate EUH codes
Specifically for mixtures: If a mixture contains ≥0.1% of a substance that is a category 2 endocrine disruptor, the label must carry the supplemental hazard statement EUH210: “Safety data sheet available on request” (Annex 6, Section 2.10)

2. PBT/vPvB SUBSTANCES - REGULATING “FOREVER CHEMICALS”

GHS CLP Rulebook 91/25 introduces mandatory labelling of substances that are persistent, bioaccumulative and toxic (Annex 1, Part 4, Section 4.3).

New statements

EUH440: “Accumulates in the environment and living organisms including in humans” (PBT properties)
EUH441: “Strongly accumulates in the environment and living organisms including in humans” (vPvB properties)

What do these abbreviations mean?

P = Persistent – does not easily degrade in the environment
B = Bioaccumulative – accumulates in living organisms
T = Toxic – harmful to living organisms
v = very – extreme persistence and bioaccumulation characteristics

Which substances fall into this category?

PFAS (per- and polyfluoroalkyl substances) – “forever chemicals”
Certain flame retardants
Certain industrial stabilisers
Heavy metals and their compounds

Precedence principle on the label

If EUH441 is assigned, EUH440 may be omitted (Annex 4, Part 1).

3. PMT/vPvM SUBSTANCES – PROTECTING WATER RESOURCES

The new rulebook also introduces labelling of substances that are persistent, mobile and toxic (Annex 1, Part 4, Section 4.4).

New statements

EUH450: “Can cause long-lasting and diffuse contamination of water resources” (PMT properties)

EUH451: “Can cause very long-lasting and diffuse contamination of water resources” (vPvM properties)

What do these abbreviations mean?

P = Persistent
M = Mobile – moves easily through soil and groundwater
T = Toxic

Which industries are most at risk?

Agriculture: Pesticides, herbicides, fungicides
Chemical industry: Industrial solvents
Detergent manufacturing: Surfactants
Pharmaceutical industry: Certain APIs

Why is this important?

These substances can contaminate water sources over a huge area and remain in the water for years. A direct impact on the quality of drinking water.

Precedence principle on the label

If EUH451 is assigned, EUH450 may be omitted (Annex 4, Part 1).

4. TITANIUM DIOXIDE (TiO₂) - NEW RULES FOR MIXTURES

GHS CLP Rulebook 91/25 introduces mandatory labelling of mixtures containing titanium dioxide (Annex 6, Section 2.12).

New statements

EUH211: “Warning! Hazardous respirable droplets may be formed when sprayed. Do not breathe spray or mist.”

(for LIQUID mixtures with ≥1% TiO₂ particles, aerodynamic diameter ≤10 μm)

EUH212: “Warning! Hazardous respirable dust may be formed when used. Do not breathe dust.”

(for SOLID mixtures with ≥1% TiO₂)

Which products does this affect?

Paints and varnishes (construction and industrial)
Construction materials (mortars, fillers, facade systems)
Cosmetic products (foundation, powder, sunscreens)
Plastics (TiO₂ as a white pigment)
Printing inks

Additional obligation

If a liquid or solid mixture with TiO₂ is NOT classified as hazardous and is not intended for the general public, but carries the EUH211 or EUH212 statement, it MUST also carry the EUH210 statement: “Safety data sheet available on request.”

DEADLINES AND ACTION PLAN

⏰ CRITICAL DATES

September 1, 2026 – Final deadline for full compliance

NOW (November-December 2025):

Inventory of the product portfolio
Check whether products contain the new classifications
Identification of priority products

Q1 2026 (January-March):

Revision of all SDSs
Update of Section 2 (Hazards identification)
Update of Section 9 (Physical and chemical properties)
Update of Section 15 (Regulatory information)

Q2 2026 (April-June):

Label redesign
Printing new labels
Employee training
Supplier checks (are they sending updated SDSs?)

Q3 2026 (July-August):

Final compliance check
Preparation for inspections

THE MOST COMMON MISTAKES COMPANIES MAKE

❌ Mistake #1: Partial updating

Many companies update only NEW products and forget that they also have to update existing products that are already on the market.

Solution: A complete revision of the ENTIRE portfolio.

❌ Mistake #2: Ignoring the supply chain

Your SDS may be perfectly updated, but if your suppliers do not provide updated SDSs for raw materials, you are not in compliance.

Solution: Proactively request updated SDSs from all suppliers.

❌ Mistake #3: Forgetting employee training

Employees need to know what the new codes mean and how to apply them.

Solution: Organised training for all relevant employees (production, QC, HSE, sales).

ADDITIONAL IMPORTANT CHANGES IN THE RULEBOOK

New precedence principles on the label (Annex 4)

Rulebook 91/25 introduces new precedence principles for labelling:

If EUH441 is assigned, EUH440 may be omitted
If EUH451 is assigned, EUH450 may be omitted

Goal: Avoiding overcrowded labels.

WHICH INDUSTRIES ARE MOST AFFECTED?

🔴 HIGH IMPACT

Plastics manufacturing – Plasticisers, stabilisers, pigments (TiO₂)
Chemical industry – Specialty chemicals, intermediates
Agriculture – Pesticides, flame retardants
Paints and varnishes – TiO₂, organic solvents

🟡 MEDIUM IMPACT

Cosmetics – UV filters, preservatives, TiO₂
Pharmaceuticals – APIs with hormonal effects
Construction – Construction materials with TiO₂
Detergents – Surfactants, additives

🟢 LOW IMPACT

Food industry – Minimal impact (unless they produce additives)
Textile industry – Low impact (unless they produce dyes/chemicals)

COMPLIANCE CHECKLIST

✅ ADMINISTRATIVE ACTIVITIES

Inventory of all products in the portfolio
Identification of products with endocrine disruptors
Identification of products with PBT/vPvB/PMT/vPvM substances
Identification of products with TiO₂

✅ DOCUMENTATION

✅ SUPPLY CHAIN

Request updated SDSs from suppliers
Check whether suppliers send accurate information
Update supplier contracts (if necessary)

✅ TRAINING AND COMMUNICATION

✅ FINALISATION

Compliance check
Archiving of old documentation
Preparation for inspections

APPLICATION DEADLINES

GHS CLP Rulebook 91/25 (Official Gazette of RS No. 91/2025):

📅 Entry into force:

The rulebook entered into force in October 2025 (8 days after publication in the Official Gazette)
From this point, the new hazard classes and categories may be applied

📅 September 1, 2026 – MANDATORY APPLICATION

What applies:

All new chemicals placed on the market from this date MUST be classified, packaged and labelled under the new rulebook (91/25)

Until this date:

The old rulebook (40/23) may be applied
You can voluntarily apply the new rulebook (91/25) already now

📅 September 1, 2028 – FINAL DEADLINE FOR “OLD STOCK”

Who this concerns:

Chemicals that were placed on the market BEFORE September 1, 2026 and
that were at that time classified, labelled and packaged under the old rulebook (40/23)

What has to be done:

The supplier must relabel and repackage those products in accordance with the new rulebook (91/25)
Final deadline: September 1, 2028

CONCLUSION: Know your deadline, plan the transition

Rulebook 91/25 brings new hazard classes that change the rules of the game – but your deadline depends on where you sell.

🌍 Three different scenarios:

Exporters to the EU:
The new EU CLP classifications already apply (May 2025 for substances, May 2026 for mixtures). You cannot wait until September 2026 – EU customers already require SDSs with EUH statements. If you export products containing ED/PBT/PMT substances, the adjustment must happen NOW.

Importers from the EU:
Your suppliers are already sending SDSs with the new classifications. You have the opportunity to move to the new system already now, without extra work – you simply carry the existing documentation over to your products.

Domestic market:

New products from 1.9.2026: The new classification is mandatory
Old products until 1.9.2028: You have time for a gradual transition

💡 Key message:

The EU does not wait for UN consensus. Endocrine disruptors, PBT and PMT get EUH statements because this is regulatory leadership, not bureaucracy. Your products with the new classification are 5-10 years ahead of the global competition.

You don’t have to be first, but you must not be last.

Plan the transition smartly – align it with the natural product life cycle (reprints, formulation changes, packaging refreshes).

SOURCE: Rulebook on the classification, packaging, labelling and advertising of chemicals and certain products in accordance with the UN Globally Harmonized System of Classification and Labelling, “Official Gazette of RS”, No. 91/2025

This blog post is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed chemical adviser or a lawyer specialising in chemical regulation.