Since 1 July 2026, the new CLP rules for digital labelling have applied. Once a machine-readable data carrier on a label or package leads to a digital label, operating that destination becomes part of compliance. Availability, privacy, language selection and resilience need to be designed as carefully as the physical print.
The most important boundary comes first: a digital label does not replace the physical hazard label. The revised CLP Regulation permits digital information as an addition and digital-only information in narrowly defined cases. Its access requirements provide a practical operating model for QR destinations and other data carriers.
What has applied since 1 July 2026
Regulation (EU) 2024/2865 was adopted on 23 October 2024, published on 20 November 2024 and entered into force on 10 December 2024. The digital-labelling rules in Articles 34a and 34b have applied since 1 July 2026 under the consolidated CLP text. The European Chemicals Agency's application-date overview gives the same date for both articles and identifies no transition period.
That date should not be confused with other CLP deadlines. Some new formatting rules for physical labels become mandatory later. For digital access, however, 1 July 2026 is the operational date.
The Regulation does not prescribe a QR code as a particular technology. It requires a machine-readable data carrier that can be read by widely used digital devices and is placed on the physical label or on the packaging next to the label. A QR code is an obvious implementation, but it is not the only one. Teams using it must control print size, contrast, error correction and durability as well as the web destination; those engineering basics are covered in our guide to QR codes on product labels.
The physical label remains the foundation
Article 34a allows suppliers to provide labelling elements digitally in addition to the physical label. Only elements explicitly identified in Section 1.6 of Annex I may appear exclusively on the digital label. In the current consolidated text, that provision concerns supplemental information under Article 25(3). Hazard pictograms, the signal word, hazard statements and precautionary statements therefore cannot simply be moved from the package to a website.
If the digital label contains information that is not present physically, the Regulation also requires wording such as “More hazard information available online”, or a similar indication, next to the data carrier. The digital extension must be recognisable as such. It must not create uncertainty about which information legally remains on the product.
A content matrix should record mandatory physical elements, digitally repeated information and permitted digital-only additions for each formulation and label version. It prevents a CMS update from changing the legal roles of package and website.
Eight operating rules for the digital destination
Provide a direct and unrestricted entry point
All labelling elements must be available together in one place and separate from other information. They must be searchable. Where information is supplied only digitally, it may be no more than two clicks away from the data carrier. A shop, campaign page or general product navigation placed before the hazard section consumes this tight click allowance and increases the risk of failure.
The destination should therefore open a dedicated hazard-information view directly. Registration, an app installation or a password is not permitted. Access must be free and available to users throughout the European Union.
Keep marketing tracking out of the route
Article 34b prohibits tracking, analysing or using information about usage for purposes beyond what is strictly necessary to provide the digital labelling. A conventional marketing stack involving profiling, retargeting, session replay or cross-device identifiers is incompatible with that boundary.
A cookie banner does not make unnecessary processing necessary. A separate, minimal delivery path without marketing tags is safer. Operational data should be limited to what is demonstrably necessary, such as aggregated availability measurements without a user profile. Purpose, fields, retention and deletion should be documented. The European Commission presents digital access as improved hazard communication, not an advertising channel.
Offer languages without demanding location data
The label must be available in the official language or languages of the Member State in which the product is placed on the market. Language selection must not depend on a user disclosing their geographical location.
A robust implementation provides a visible language switcher and may use the browser language as a non-binding preference. IP geolocation, GPS prompts or a mandatory country dialog are neither necessary nor appropriate. Each approved language version should remain available at a stable URL, and changing language must not redirect the user to a generic home page.
Support major devices and browsers
The digital label must be accessible through all major operating systems and browsers. That rules out app-only solutions. Core information should work as semantic HTML before optional scripts load.
Acceptance testing should cover major browsers on iOS, Android, Windows and macOS, small screens, enlarged text and the critical route with JavaScript disabled. The scan and destination must be tested separately: a good QR code is of little value if a certificate error or redirect loop blocks the page.
Design for vulnerable groups
The Regulation requires the needs of vulnerable groups to be addressed. In practice, that calls for an accessible information hierarchy, adequate contrast, scalable type, meaningful headings, keyboard operation and intelligible alternatives for non-text content. Hazard information must not be communicated by colour alone or hidden inside a complex interactive graphic.
Accessibility is not a design correction to add later. The content model, translations and technical templates must work together so that warnings remain understandable with a screen reader or strong magnification.
Keep information available for ten years
The digital label must remain available for at least ten years. Other Union legislation may require a longer period. A short-lived campaign URL or an unversioned product page is unsuitable for that responsibility.
The data carrier should resolve to a stable address under controlled ownership. Changes to a formulation, classification or supplier data must not retroactively replace the labelling for older batches. This requires immutable versions, a traceable relationship between batch and labelling state, and retention rules covering content, media, redirects and domains. A domain change is not merely a rebranding exercise; it is a migration risk for products already in the market.
Provide a real fallback for outages
For labelling elements provided only digitally, Article 34a requires an alternative means of access on oral or written request. That duty also applies when the digital label is temporarily unavailable at the time of purchase. The alternative must be independent of a purchase and free of charge.
Technical monitoring alone is therefore insufficient. Retailers, support teams and quality management need an agreed process: who detects the outage, who supplies the correct product and language version, through which channel, and how is the event recorded? A printable, versioned document may be part of this fallback layer if it is available without a purchase requirement or unnecessary barriers.
Separate regulated content from advertising
Labelling elements must be separate from other information. That weighs against landing pages where warnings sit among product photography, recommendations and purchase buttons. A safer architecture separates the legally controlled labelling area from editorial or commercial modules—technically, visually and in its approval workflow.
An acceptance model before release
Before printing, each product should undergo an end-to-end test. The real data carrier is scanned at a typical distance and under poor lighting. The test then confirms that the correct product and language version appears without sign-in, that the labelling is available within two clicks, that no unnecessary trackers load, and that every page resource works over HTTPS.
The organisation also needs a long-term test. Is the domain secured for the retention period? Can an old version be restored? Does monitoring detect certificate, DNS, redirect and content failures? Does the free fallback work without an order number?
This kind of test turns a web publication into a controlled labelling process. It connects regulatory affairs, product safety, packaging engineering, IT and customer service through a shared release record.
The practical consequence
The rules applying since 1 July 2026 are not permission to remove hazard information from physical labels. They define a narrow but useful digital extension. Its quality is not measured by scan counts, but by whether people can reach the correct information without an account, tracking, location disclosure or technical obstacles—today and ten years from now.
Companies should therefore treat the data carrier as a long-lived product component. A stable address, versioned content, data-minimising delivery, accessible presentation and a rehearsed outage process are not optional web features. They are the operating foundation of dependable digital CLP labelling.
Sources
EUR-Lex: Consolidated text of Regulation (EU) 2024/2865 as of 23 December 2025
ECHA: Application dates of certain specific CLP provisions
European Commission: Classification, labelling and packaging of chemicals
European Commission, 10 December 2024: Revised chemical labelling regulation enters into force
