The recent proposal to revise the REACH regulations has stirred significant reactions across the European chemicals industry.

Presented during the 54th meeting of the CARACAL on April 3rd 2025, these changes are intended to update and modernise the regulation that has been the central EU chemicals legislation for two decades.

 

“On 3 April, the European Commission services presented their latest thinking on the revision of the REACH Regulation during a meeting of CARACAL – the expert group of Competent Authorities for REACH and CLP, which advises the Commission on chemical legislation.

From what we have heard today at CARACAL, it seems that the Commission services are living in a different world than their own political leadership and President.

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.

It’s as if there is no Competitiveness Compass, no Clean Industrial Deal, no economic crisis whatsoever. As if the High-Level Dialogue with Commissioner Roswall and EVP Séjourné didn’t even take place.

We are truly shocked.”

CEFIC

 

Key Revisions & Their Implications

The European Commission (DG Env), has outlined critical areas of focus in the proposed REACH revision package.

• Simplification of Obligations

  The revision seeks to streamline the process for both industry players and regulatory authorities. However, initial feedback suggests that the proposed changes might complicate compliance efforts, especially for small and medium enterprises (SMEs).

   

• Updating REACH Annexes

  Proposed changes aim to modernise the information requirements, which include deleting Annexes III and XIII and revising others to enhance clarity and enforcement.

   

• Clarity on PFAS (Per- and Polyfluoroalkyl Substances)

  Specific attention is being paid to chemicals with widespread use and significant environmental persistence.

REACH Registration

Several proposed modifications will have significant impact within the industry.

• Ten-Year Registration Validity

  Registrations may now be subject to expiry of validation after 10 years, and possible revocation contingent upon various factors such as completeness checks and non-compliance following evaluation decisions. The criteria for revocation need to be clearly defined to ensure transparency.

   

• Mandatory Dossier Updates

  Following the identification of substances as SVHCs (Substances of Very High Concern) or decisions on harmonized classification, updates will become obligatory.

   

• Testing Proposals

  The requirements for testing proposals will be extended to all in-vivo testing including Annex VII and VIII data requirements.

   

• Structural changes to REACH Annexes

  These include the deletion of Annexes III and XIII and updates to Annexes I, VI–X, and XI.

   

• Increased Assessment

  Chemical Safety Assessment to include persistent, mobile, and toxic (PMT) and very persistent, very mobile (vPvM) and Endocrine Disruptors (EDs) assessment.

   

• Nanoforms

  Update to the legislation introducing the definition of a nanomaterial from the 2022 commission recommendation and adding the definition for the nanoform of a substance accordingly.

   

• Polymer Regulation

  Introducing mandatory notifications for all polymers produced or imported above one tonne per year and registrations for polymers falling under the criteria for ‘Polymers requiring registration’ (PRR). The additional cost could be profound for polymer importers or manufacturers who have already spent significant amounts on registration of the monomers.

This non-exhaustive snapshot seems to demonstrate an increased burden on industry to sustain their compliance, which is particularly a concern for SMEs, for authorities in their enforcement responsibilities, and for ECHA in their administration of increased updates in addition to polymer REACH.  

With the changes however, we must also consider whether they will in-fact benefit the stated aims of REACH, to maintain market access for companies wishing to place chemicals on the EU market whilst preserving safe use of those chemicals, protecting human health and the environment.

Significant Shift for Chemical Regulations in the EU

The proposed REACH revisions mark a significant shift in the regulatory landscape for chemicals in the EU. As the industry navigates these changes, Blue Frog Scientific is here to provide guidance and expert advice. We encourage businesses to engage with the consultation process and begin strategising on compliance under the revised regulations.

For further insights into the REACH revisions and to discuss how these changes might affect your business, contact Blue Frog and one of our REACH Regulatory Consultants will help ensure that your business remains compliant and competitive in this evolving regulatory environment.