On 8 July 2025, the EU Commission published its Chemicals Industry Action Plan (CIAP), setting out a roadmap for a more sustainable, competitive, and resilient EU chemicals sector, The plan is accompanied by the 6th Omnibus package aimed at simplifying certain formal requirements, such as labelling requirements, and shall be followed shortly by a proposal for a new so-called European Chemicals Agency (ECHA) Basic Regulation.

The CIAP is another cornerstone in the Commission's broader industrial strategy to enhance competitiveness, sustainability and resilience across key EU sectors, following similar action plans for the automotive (see blog post by Claire Diez-Polte and Nico Ruepp), steel and metals and broader industrial sectors. For the chemicals sector specifically, stakeholders should also note the ongoing recast-process for the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Regulation (EC) No 1907/2006 with the EU Commission's proposal expected in Q4 2025.

These developments may have significant implications for product compliance, sustainability and supply chain obligations as well as international trade. Below, we summarize the key changes and recommend how businesses should prepare.

 

Product compliance

6th Omnibus Proposal: Simplification of the CLP Regulation

The Classification, Labelling and Packaging (CLP) Regulation (EC) No 1272/2008, governs classification of substances and mixtures, as well as their labelling and packaging. The 6th Omnibus Proposal introduces the following key changes:

  • Streamlined and simplified formatting and labelling rules (e.g., exemptions for font sizes, line spacing, packaging)
  • Introduction of a digital contact point on product labels to support digital transformation and improve communication with enforcement authorities
  • Simplified hazard communication requirements for advertisements and distance sales.

New ECHA Regulation

The Commission proposes a stand alone regulation for ECHA to improve governance, financial structures and efficiency.

  • ECHA will gain enhanced responsibilities for notification, registration, scientific evaluation and coordination with EU market surveillance authorities.
  • Currently, ECHA's mandate is scattered across different pieces of legislation, primarily REACH; the new regulation consolidates and expands its role.
  • The proposal is expected to be published by the EU Commission in Q3 2025.

REACH Recast Process – Proposal to be expected by end of 2025

The ongoing revision of the REACH Regulation aims to modernize processes in light of safety, security and sustainability aspects, including:

  • Extension of the Generic Risk Approach to more substances of concern (e.g., Persistent, Bioaccumulative, and Toxic substances (PBTs), Persistent, Mobile, and Toxic substances (PMTs)) as well as professional uses.
  • Introduction of digital data safety sheets for better access to compliance data (e.g., Substances of Very High Concern (SVHC) content, registration status) in line with the Digital Product Passport.
  • Extended scope for notification and registration obligations, notably for certain polymers.

 

Sustainability and supply chain

Circular Economy Act

Currently, the chemicals industry depends significantly on virgin, fossil-based materials. In order to promote chemical recycling efforts and the use of secondary materials, the EU Commission is preparing a Circular Economy Act (planned for 2026) alongside an implementing act under the Single-use Plastics Directive (expected in Q4 2025). This initiative builds on the existing EU Circular Economy Action Plan from 2020. Also, it is worth noting that various EU Member States have adopted their national circular economy strategies, most recently Germany, that will likely play a role in the legislative process.

Per- and Polyfluoroalkyl Substances (PFAS) Phase-Out Strategy

Following the comprehensive PFAS restriction proposal by national authorities in 2023, the Commission will pursue a dual approach: reducing PFAS use and mitigating risks, while supporting development of industrial scale safe alternatives where no substitutes exist today.

Digital Product Passport

Introduced by the Ecodesign Regulation (EU) 2024/1781, the Digital Product Passport will enhance supply chain transparency. Companies should already start mapping product data needed for compliance.

 

International trade

Critical Chemicals Alliance – a new instrument in securing EU competitiveness

By end of 2025, the Commission plans to establish a Critical Chemicals Alliance — a forum for Member States and stakeholders to address supply chain risks, identify critical production sites and reduce import dependencies through diversification. This will feed into a planned Critical Molecules Act, modelled on the Critical Raw Materials Act (Regulation (EU) 2024/1252) (CRMA) – please see our client alert on the CRMA here to render supply chains more resilient and secure EU chemical production capacity.

Chemical raw materials in trade agreements

The EU Commission will prioritize the access to raw materials that are critical for the chemicals industry in negotiations on Free Trade Agreements, as well as in alternative cooperation agreements and partnerships (e.g., Clean Trade and Investment Partnerships).

Trade defense and Import Surveillance Task Force

The newly introduced Import Surveillance Task Force, operational since March 2025, is responsible for monitoring potential trade diversions, i.e., harmful foreign trade practices such as price dumping. The monitoring shall include in particular a list of critical molecules to enable the EU Commission to act swiftly and decisively on trade defense measures.

Stronger border control and market surveillance

There is a general trend to increase border control and market surveillance to close loopholes and ensure compliance of imported products. In this vein, the EU Commission considers setting up a centralized EU Market Surveillance Authority, to complement the existing national authorities.

 

How should businesses prepare?

  • Engage in the various legislative processes through public consultation
    Stakeholders can participate in public consultation through the EU Commission's Have Your Say portal or in targeted consultation processes. This ensures that the industry's voice and perspective are heard, and legislation becomes more efficient.
  • Assess product portfolio
    Map all substances and mixtures that could be affected by the new CLP and REACH obligations, including SVHCs, polymers and PFAS related substances.
  • Prepare compliance systems
    Plan updates to labelling, safety data sheets, and internal classification/registration procedures. Assess readiness for digital reporting and the Digital Product Passport.
  • Monitor further legislative developments
    Stay informed about the upcoming legislative packages, particularly the Circular Economy Act, Critical Molecules Act, and further omnibus packages aiming to reduce administrative burdens in environmental law. 
  • Review governance and supply chain strategies
    Ensure your ESG and trade compliance programs are aligned with emerging EU sustainability and trade policy objectives.

 

 

Our international trade, compliance and sustainability team is happy to support you navigate the upcoming changes.

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