From 1 January 2026 the employer no longer has to seek prior approval or notify the Danish Working Environment Authority of work with certain carcinogenic substances, and titanium dioxide has been removed from the list of carcinogenic substances. The workplace instruction sheet, on the other hand, was abolished back on 1 July 2019. Here is what has actually changed — and what has not.
Introduction
From 1 January 2026 a new executive order on carcinogenic substances and materials applies (BEK no. 1347 of 24 November 2025); since 27 June 2026 it has been replaced by BEK no. 582/2026. For the cleaning trade, which uses many classified products, it is important to know exactly what has changed — and what has NOT.
What has changed?
| Change | What it means |
|---|---|
| Requirements for prior approval/notification are waived | The employer no longer has to apply to the Danish Working Environment Authority for prior approval or notify work with certain carcinogenic substances and materials. The Ministry of Environment's poison rules on reporting still apply. |
| Titanium dioxide is removed from the list | Titanium dioxide has been removed from Annex 1 of the executive order on carcinogenic substances, because the EU Court of Justice ruled in August 2025 that the substance should not be classified as a suspected carcinogen. |
| The workplace instruction sheet — not a 2026 change | The requirement for workplace instruction sheets was repealed on 1 July 2019 (BEK no. 254/2019). Since then, the chemical part of the APV with a register of the hazardous substances and references to the safety data sheets (today BEK no. 581/2026 § 6, subsection 4) and training and instruction (§ 23) apply. |
What is NOT changed?
- 01The obligation to create and document a thorough chemical risk assessment — it remains.
- 02The requirement to instruct employees about chemical hazards.
- 03CLP/REACH rules and SDS obligation (safety data sheet with 16 points is still required).
- 04The Labour Authority's requirements for personal protective equipment for chemical risk.
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