CLP Refill 2026 – refill stations, hazard class interlock and label control | Word/PDF/Excel

Do you sell or plan to sell cleaning products or other chemical products via a refill station? The EU's updated CLP Regulation has specific conditions for hazardous substances and mixtures that are refilled in-store or by a professional supplier. From 1 July 2026, Article 35.2a and Annex II, Section 3.4(a–k) apply. This product is a practical documentation package for assessing each product, station, and container—not a general authorization to sell chemicals as refills.

You get 15 customer files in a digital ZIP: five Swedish control templates, one Swedish user guide and one English User Guide in Word and searchable PDF, plus an Excel workbook with nine tabs. 7 DOCX + 7 PDF + 1 XLSX. The PDFs are printable and searchable but not interactively fillable. The Word files are editable.

Who Is the Template Intended For?

Stores with chemical refilling, cleaning product refill stores, distributors of hazardous mixtures, cleaning wholesalers, operators of refilling machines, and environmental, quality, and chemical coordinators. Pay particular attention to which operator is the supplier under CLP and who is actually responsible for the station and refilling.

What Does CLP Say from 1 July 2026?

CLP (EC) No 1272/2008 Article 35.2a and Annex II 3.4 were amended by Regulation (EU) 2024/2865. According to the Swedish Chemicals Agency, the specific refill requirements apply from 1 July 2026. Other CLP rules have later dates—including certain distributor rules on poison information from 2027 and certain changes postponed until 2028. This package addresses refilling and does not mix up the dates.

Eleven Checks Before and During Refilling—Annex II, Point 3.4(a–k)

• (a–b) Station label: correct hazard labeling for each product, visible and fixed according to CLP.
• (c–d) Safety: measures against exposure to people and the environment, especially uncontrolled child access.
• (e–f) Immediate assistance: the supplier must be able to help on-site during refilling; special conditions apply for immediate help outdoors and outside opening hours.
• (g–h) Compatibility and competence: avoid dangerous reactions between substances/mixtures and ensure staff are correctly trained.
• (i–j) Customer packaging: each refilled container must have CLP-compliant hazard labeling and packaging.
• (k) Prohibited hazard classes: certain chemical products may not be provided via a refill station at all, even if the station otherwise has good safety measures.

Which Chemicals May Not Be Sold via a Refill Station?

Annex II, Section 3.4(k) covers 20 prohibited hazard classes or differentiations: acute toxicity, specific organ toxicity (single or repeated exposure), skin corrosion category 1, serious eye damage category 1, respiratory and skin sensitization, aspiration hazard, mutagenicity, carcinogenicity, reproductive toxicity, flammable gases, flammable liquids category 1–2, flammable solids, and endocrine-disrupting and PBT/vPvB/PMT/vPvM properties. For some groups, all categories apply. The complete and carefully differentiated 20-point list is available in the Swedish guide and the Excel tab “Prohibitions 3.4k”; check the current official classification and source text before use. For example, a skin-sensitizing product may be prohibited as a refill even if staff are on site.

What Is Included—Document by Document?

Excel with Nine Tabs

Start: overview and number of registered cards. Products: classification and manual review. Stations: signage, child safety, staffing, and chemical safety. Labels: control of refilled packaging. Training: staff competence and drills. Refill log: secure process ID for refills. Non-conformances: product/station block, actions, and dates. Prohibitions 3.4k: complete list of 20 prohibited hazard groups. Sources: current official legal sources.

730 built-in formulas check registration status and can display “STOP – NO REFILL” for a registered prohibited class or uncertain classification. If fields are present, the status may become “Supporting documentation registered – MANUAL REVIEW”; this does not mean that the product, station, or container has been approved. The workbook has been tested with a prohibited class, registered documentation, missing documentation, and an empty customer row. The customer file contains no fictitious cases.

Three Realistic Use Cases

1. A skin-sensitizing cleaning product: the supplier has correct labels and spill trays, but the mixture’s classification shows a prohibited group under 3.4(k). The product’s refill must be blocked regardless of the station’s safety measures.
2. A product with an outdated safety data sheet: no one can determine if it is covered by a prohibited group. The product receives an internal block, and the classification is investigated before continued handling.
3. A chemical without an identified prohibited class, but in the wrong container: the customer wants to fill a previously used and unlabeled bottle. The check according to Section III–IV and Annex II 3.4(i–j) is missing; the refilling is not carried out.

Workflow—From Classification to Operation

1. Determine whether it is a hazardous substance or a hazardous mixture and whether Article 35.2a applies.
2. Test the product’s latest classification against all 20 block groups; check the current SDS, harmonized classification, and supplier information.
3. Conduct a station inspection—especially child safety, labels, staff presence, and the availability of immediate assistance.
4. Verify that each container receives correct hazard labeling and meets CLP packaging requirements.
5. Conduct training and practice realistic but harmless scenarios.
6. Document non-conformances and voluntary internal blocks; let the responsible person decide on correction and re-assessment.
7. Continuously monitor changes in product classification, label version, station design, and packaging requirements.

Frequently Asked Questions About Chemical Refilling

Can all cleaning products be sold as refills?

No. Hazardous products with any of the 20 prohibited hazard groups under CLP Annex II 3.4(k) may not be provided in this way. Other legal requirements and packaging conditions must also be assessed.

Did the refill rules start in 2026 or 2028?

The specific refill rules began to apply on 1 July 2026. Other CLP requirements have been postponed until 2028, but these should not be confused with Article 35.2a and Annex II, Section 3.4.

Is a label on the machine enough?

No. Each refilled package must also meet CLP requirements for hazard labeling and packaging. Check, among other things, product identity, hazard information, material compatibility, and relevant sealing requirements.

Can the station be used without staff during evening hours?

The rules require immediate assistance, with special conditions for stations operating outdoors or outside regular opening hours. An unstaffed station therefore cannot be assumed to be permitted.

Is a product without prohibited hazard classes automatically approved?

No. The product’s complete classification, station requirements, container labeling and packaging, and other applicable regulations must also be assessed.

Does Excel perform a legal classification of the chemical?

No. The classification must be verified by the responsible person against current sources. Excel records the human assessment and blocks certain choices, but it does not determine the chemical’s actual hazard properties itself.

Are the PDF files digitally fillable? Are the templates available in English?

The PDFs are searchable and printable, not electronically fillable. Word is editable. The five work templates and Excel are in Swedish; the English User Guide is included separately.

Is a separate UFI or PCN check required?

Yes, where obligations apply, such information and any new distributor rules must be assessed separately. This package does not replace the product’s safety data sheet, poison information, biocidal regulations, detergent-specific requirements, or REACH.

Related Document Templates

For companies that also sell chemicals online, CLP e-commerce—hazard information and product pages is available. For distributors who relabel or sell hazardous mixtures, CLP—UFI, PCN, and poison information is available. This product, however, is aimed at physical refill stations, hazard class blocks, and each refilled package.

Official Legal Sources, Dates, and Limitation of Liability

CLP (EC) 1272/2008, Article 35.2a, Section III–IV, and Annex II 3.4(a–k); amendment (EU) 2024/2865; the Swedish Chemicals Agency’s updated CLP guidance and ECHA’s application dates.

Version 1.0, AI-assisted legal source check, 12 November 2026. No external lawyer, chemical expert, or authority has certified or approved the product. It is not a safety data sheet, finished hazard label, or permit. The user’s actual products and stations must be assessed individually. The digital ZIP is linked to the delivery app only after a separate publication decision.