Chemical compliance

What’s happening? Here is an update for September 2025:

Simplification: Commission unveils action plan and package for chemicals industry
EU REACH: updated PFAS restriction proposal published
EU REACH: three new hazardous chemicals on the Candidate List

Simplification: Commission unveils action plan and package for chemicals industry

In July 2025, the European Commission presented an Action Plan for the Chemicals Industry to strengthen the competitiveness and modernisation of the EU chemical sector.

The Action Plan addresses key challenges, namely high energy costs, unfair global competition, and weak demand, while promoting investment in innovation and sustainability.

The full version of the Action Plan is published here.

The plan proposes the following measures:

Resilience and level playing field

Establishing a Critical Chemical Alliance that will identify critical production sites needing policy support and tackle trade issues like supply chain dependencies and distortions through trade defence measures.

Affordable energy and decarbonisation

Implementing the Affordable Energy Action Plan to help reduce high energy and feedstock costs.

The EU has clarified the rules for low-carbon hydrogen and will update state aid to lower electricity costs for more chemical producers by the end of the year.

The plan also encourages using clean carbon sources like carbon capture, biomass and waste, alongside support for renewables.

Lead markets and innovation

Highlighting fiscal incentives and tax measures to boost demand for clean chemicals.

The upcoming Industry Decarbonisation Accelerator Act, Bioeconomy Strategy and Circular Economy Act will boost sustainability, resource efficiency and chemicals recycling among others.

Per- and polyfluoroalkyl substances (PFAS)

Continuing action on phasing out and minimising PFAS emissions through a robust, science-based restriction, while allowing use in critical applications under strict conditions where no alternatives are available.

See article below on ECHA’s updated restriction proposal.

The EU Commission will also launch EU Innovation and Substitution Hubs and mobilise EU funding under Horizon Europe (2025–2027) to accelerate the development of safer, more sustainable chemical substitutes.

Simplification of certain requirements and procedures for chemical products

The Chemical Industry Action Plan is accompanied by a simplification package, the 6th Omnibus.

The aim is to further streamline and simplify key EU chemicals legislation, reducing compliance costs and administrative burdens for the chemical industry, while ensuring strong protection of human health and the environment.

The measures include:

• simplifying hazardous chemical labelling rules clarifying EU cosmetics regulations, and
• easing registration for EU fertilising products by aligning information requirements with standard REACH rules for chemicals

The full set of legislative documents is available here.

The European Commission has highlighted that the chemicals sector is vital to Europe’s economy. It underpins the manufacture of almost all goods and provides essential materials and technologies to industries that support the welfare, security and resilience of European economies.

EU REACH: Updated PFAS restriction proposal published

On 20 August 2025, the European Chemicals Agency (ECHA) published the updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under EU REACH.

The restriction proposal was originally submitted to ECHA in 2023 and aims to reduce PFAS emissions into the environment.

Following formal consultation in 2023, and heated debate among industry, the initial restriction proposal was updated to account for over 5,600 scientific and technical comments from third parties and newly gathered evidence.

The update includes:

• Assessments for eight additional sectors, some of which are particularly relevant to Landbell Group’s clients:
  • printing, sealing and machinery applications
  • medical applications, such as immediate packaging and excipients for pharmaceuticals
  • technical textiles, and
  • broader industrial uses, such as solvents and catalysts

• Consideration of alternative restriction options (beyond a full ban or a ban with time-limited derogations) for certain applications, including manufacturing, transport, electronics and semiconductors, sealing and machinery applications, and technical textiles. Such options may allow for conditional continued manufacture, supply or use of PFAS where the risks can be controlled.

EU REACH: three new hazardous chemicals on the Candidate List

The European Chemicals Agency (ECHA) has added three hazardous substances to the Candidate List of substances of very high concern (SVHC) for Authorisation.

Two newly added substances are very persistent and very bioaccumulative.

They are used, for example, in cosmetics, personal care products and in automotive care products.

One substance is toxic for reproduction and is used in textile treatment products and dyes.

See more information on the recent update here.

The list currently contains 250 entries for hazardous chemicals, some of them are groups so the actual number of substances is higher.

What does it mean for companies?

European producers, importers and suppliers of products containing a Candidate List substance above a concentration of 0.1 % (weight by weight) must:

• inform their customers of its presence, provide sufficient information on safe use, and notify ECHA within 6 months of the inclusion on the list (under REACH Regulation)
• update the safety data sheet (SDS) if the substance is supplied on its own or in mixtures, and
• submit notification to ECHA’s database of substances of concern in products, SCIP (under Waste Framework Directive)

Products containing SVHCs cannot have the ecolabel award (under Ecolabel Regulation).

The substance may be placed on the Authorisation List in the future. If so, its use will be prohibited unless a company obtains authorisation for its use from the European Commission.