On April 3, 2025, the European Commission’s proposals for REACH revision sparked fierce debate at the 54th meeting of Competent Authorities for REACH and CLP (CARACAL-54). As the first comprehensive revision proposal to the REACH Regulation in nearly two decades of implementation, the revision primarily seek to address structural conflicts in the current regulatory framework.
The proposal mainly covers key areas including registration updates, nanomaterials, digitalization and simplification of supply chain communication, streamlined authorization and restriction procedures, and enhanced customs enforcement. The details are shown below:
| Revision point | Content |
Registration
| Registration shall stay valid for 10 years. ECHA may revoke registration number if the dossier has not been updated or found incompliant; Require notification of all polymers >1 ton/yr and identify polymers requiring registration based on cirteria indicating a hazard; Require new dossier update for SVHC substance; Encourage data sharing and minising animal testing; Delete Annexes II and XIII, modify Annexes I, VI, VII-X and XI on information requirement, and modify Annex II to adapt to CLP and UN-GHS updates.
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| Nanomaterials | Introduce definition of nanomaterial from 2022 Commission Recommendation; Clarify reporting requirements for downstream users, notably on characterisation and chemical safety assessment.
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| Evaluation | ECHA can revoke registratino number in cases of persistent non-compliance with evaluation; Include option to request specific adaptation (e.g., read-across) rather than test for testing proposals and completeness check; Clarify that justification to select substance for substance evaluation can be based on potential hazard, structurally similar substances, constituents, degradation products or groups of substances; Clarify process and expectation in specific situations (e.g. cease manufacture during decision making).
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| Authorization | Introduce Role of Regulatory Management Options Analysis (RMOA) and discussion/decision on best regulatory options; Consider changing prioritisation criteria in Article 58(3) focusing on substances with high volumes, low/limited number of users and uses, with potential to be used as alternatives for substances in Annex XIV; Transitional period to cease the use in case of refusal of authorisation.
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| Restriction | Use generic risk management approach for substances with certain hazard classes in consumer uses; Provide upfront information on use, exposure and alternatives before submitting restriction proposals.
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| Digitalization and simplification of supply chain communication | |
| Enhanced customs enforcement | Introduce provision for importers to provide SDS during customs controls. Automated verification and control of registration and authorisation numbers by customs; Interconnection of electronic systems (REACH–EU Single Window Environment for Customs); Strengthened administrative cooperation between customs authorities and other authorities responsible for official controls, for the controls of restrictions (Annex XVII REACH).
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While regulators framed the revisions as critical modernizations to streamline compliance and enforcement, Europe's chemical industries denounced the reform as "absurd" and economically tone-deaf.
According to European Chemical Industry Council (Cefic), "The REACH proposals made today will massively increase the administrative burden for industry and SMEs in particular, calling the proposals 'simplification' is absurd. Most of what was presented is identical to proposals made three years ago."
Cost surges from DPP, mandatory polymer compliance, and decennial registration renewals, technical gridlock in standardizing customs automation protocols, the widening gap between Brussels' regulatory ambitions and on-the-ground operational viability underscores a sobering reality: translating these proposals into enforceable rules will require navigating a labyrinth of technical, economic, and geopolitical hurdles.
Next step
The draft will proceed to member state negotiations and public consultation, with stakeholder feedback due by the April 25 deadline; final legislation is expected by the end of 2025.
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