Is it too late if my certification is still running on 27 September 2026?

It is not too late, but it is not a free pass either.

The rules apply from 27 September 2026, including to goods manufactured, ordered or distributed before that date. There is no general transition or sell-off period.

In June 2026 the national authorities in the European Consumer Protection Cooperation Network (CPC) published a common understanding on old stock. It states that enforcement may be phased where genuine and specific transitional difficulties exist, and that authorities may take into account a trader’s role, size, available resources and concrete efforts to comply in good faith. As evidence of such efforts the paper expressly names records showing the steps taken and their timing, internal compliance policies, substantiation work and other compliance initiatives.

What that means for a certification in progress

A process that has been started, with a dated enquiry, laboratory testing commissioned and the conformity assessment under way, is exactly that kind of documented substantiation work. A company visibly pursuing the evidence stands in a different position from one that has done nothing.

What it does not mean

A certification in progress does not make an impermissible claim permissible and does not automatically protect against enforcement. The paper concerns old stock and genuine, specific transitional difficulties; it is neither a formal position of the network nor a binding interpretation of the directive, and it does not bind the courts. For packaging newly designed after the application date it does not apply at all.

A sensible order of work until then

Correct the claims online first: they come first in the authorities’ own list because they can be changed without lead time. Then promotional and sales materials, then future packaging and new orders. The free claim check assesses up to five claims and shows which of them are critical in the first place.