From 2027, distributors must notify

Direct answer: Under the revised CLP Regulation, from 1 January 2027 a distributor who changes a product's trade name or labelling, or places it on the market in a member state where it has not been notified, must submit a poison centre notification, unless they can show the poison centres already hold the information.

Who is affected

Private-label retailers, wholesalers who relabel, e-commerce sellers who import from another member state, and anyone who sells a supplier's product under their own brand. Until now these companies could rely on the manufacturer's notification.

What you need from your supplier

The supplier's UFI and, ideally, their notification details. If the composition and classification are unchanged, your notification references the same formulation. If the supplier will not share composition, the mixture-in-mixture rules let you notify with the supplier's UFI and the information from their SDS.

What to do before 2027

1. List every product you sell under your own name or into a country the supplier has not covered.
2. Ask suppliers for UFIs and confirmation of which countries they have notified.
3. Set up your ECHA account and legal entity.
4. Prepare the notifications in batches; the cost is mostly in the first one.

This change is not affected by the Omnibus simplification proposals.