Navigating the EU’s Sweeping REACH Reform Proposals in Chemical Industry

Introduction

In a significant development for chemical regulation in the European Union, the European Commission has unveiled its long-anticipated proposal to revise the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. The EU REACH reform proposal was presented at a recent CARACAL meeting, the key advisory forum for EU chemicals legislation, marking the first comprehensive overhaul of REACH in nearly two decades.

What’s in the Proposed EU REACH Reform?

The revision aims to address structural shortcomings in the existing system while aligning EU chemicals management with sustainability goals, supply chain digitalization, and enhanced enforcement. However, industry stakeholders warn that the practical challenges and cost implications may outweigh the intended benefits.

Key Changes of EU REACH

• All REACH registrations will be valid for 10 years. Companies must update dossiers proactively, or risk revocation of registration numbers by ECHA.
• Polymer notification becomes mandatory: Companies importing or producing polymers above 1 tonne/year must notify and, based on hazard classification, proceed to full registration.
• Mandatory dossier updates include:
  • Substance listed as an SVHC (Substance of Very High Concern)
  • 1–10 tonne registrations using minimal data must be upgraded to full Annex VII requirements
• Proposed removal of Annexes III and XIII, and updates to Annexes I, VI–X, and XI
• Proposes the Digital Product Passport (DPP) system and electronic Safety Data Sheet (e-SDS) format to streamline information exchange.

Industry Reactions to the EU REACH Reform

While EU regulators describe the proposed reforms as a step toward a “simple and modernized chemicals framework”, industry voices are raising red flags. Trade associations argue that several proposed changes—such as the 10-year registration validity, polymer registration, and digital compliance infrastructure—could impose excessive costs, technological burdens, and new trade barriers.

What’s Next?

The proposal has now entered the public consultation until April 25, 2025. Final legislative texts are expected to be published by late 2025, but implementation could stretch well beyond that, depending on feedback and political negotiations.

Companies are advised to:

• Closely monitor developments and draft compliance scenarios
• Engage in public consultations to voice concerns or suggest improvements

About CARACAL

The Competent Authorities for REACH and CLP (CARACAL) is the EU’s key advisory body for chemicals legislation. As a platform where future legislative trends are shaped, CARACAL’s discussions often provide early insights into regulatory shifts.

Final Thoughts

The EU REACH reform proposal marks a turning point in how Europe regulates chemicals. While the intent to modernize and harmonize is clear, the gap between policy ambition and industrial reality remains a significant hurdle.

As one of the most complex regulatory environments globally, EU chemicals policy continues to evolve. Businesses that stay informed, proactive, and digitally ready will be best positioned to thrive in this next chapter of REACH compliance.