The Blog

Last week, our Senior Legal Advisor Tim Becker from REACHLaw Finland was invited to provide an overview of the latest developments on chemical regulations in the EU and selected third countries at the WSM Online Seminar on Chemicals Law & Materials Compliance 2025.

In a nutshell

The full-day seminar in German language took place against the timely background of the European Chemicals Industry Action Plan released by the European Commission on 8 July.

The event attracted more than 90 registered participants representing member companies – incl. many SMEs – of the professional associations of the German Association of the Steel and Metal Processing Industry (WSM Wirtschaftsverband Stahl- und Metallverarbeitung e.V./Düsseldorf). Other invited contributors included experts from the Federal Institute for Occupational Safety and Health (BAuA), VIA Consult GmbH & Co. KG and KION Group.

The main objective of the seminar was to shed light on and discuss key relevant chemicals regulatory requirements and evolutions, including but not limited to EU REACH, and show how they can be integrated into company processes from purchasing to sales.

Highlights

Update on EU REACH basic requirements and tasks in the application (BAuA, Dortmund)

Dr. Anja Hackmann from the REACH-CLP-Biozid Helpdesk at the Federal Office for Chemicals of the Federal Institute for Occupational Safety and Health (BAuA) provided a basic overview of the different EU REACH processes with SMEs in mind. Regarding Restrictions of chemicals, she pointed to the paradigm shift over time from a reactive approach using bans to the increased focus on the precautionary principle with differentiated risk management measures such as specific use bans, limit values and (other) worker protection measures under EU REACH today. The recent additions to the REACH Restrictions list (Annex XVII) – which now has 81 entries in total – were mentioned: Synthetic polymer microparticles, PFHxA, DMAC and NEP. 

REACH+: Current developments in chemicals law in the EU and in selected third countries (REACHLaw, Helsinki)

Following on from BAuA’s presentation, our Senior Legal Advisor Tim Becker started by taking a bird’s eye view on EU chemical policy which today is characterised by a high number of regulations and initiatives, not limited to REACH and CLP, which need to balance different priorities from health and environmental protection to wider sustainability and – not least – competitiveness. As an example, the EU REACH Revision, which was delayed several times under the previous European Commission, is now primarily intended to “simplify REACH” for the chemicals industry without compromising on safety and environmental protection. The Commission proposal is expected in Q4 2025. In the meantime, the Commission has published a European Chemicals Industry Action Plan on 8 July 2025.

In the second part of his presentation Tim focused on the current state of play of two key group restriction proposals in the EU: “Universal PFAS” and certain chromium(VI) oxides, oxyacids and salts. While the former proposal is currently with the ECHA Scientific Committees for opinion-development on a sector-by-sector basis (expected to conclude by 2026), the latter is subject to an on-going ECHA public consultation until 18 December 2025. Recent substance additions to the Stockholm Convention on Persistent Organic Pollutants and the regulatory status of lead metal under different laws (REACH, RoHS, OSH, Batteries Regulation, etc.) were also presented. Tim also cautioned participants to a new EU-wide enforcement project (REF-15) on workplace safety – including SDS, authorisations and restrictions – which is scheduled to start in 2026.

Regarding requirements for Substances of Concern (SoCs), Tim reflected on the wide definitions and implementation state of play under various EU regulations, highlighting the on-going ECHA work for SoCs in batteries and packaging, and activities under ESPR to set SoC information requirements for specific product groups. Further information on SoCs is available in Tim’s article of 2024 (link). In relation to ESPR, the preparatory work for iron and steel products and the introduction of the Digital Product Passport were also highlighted, inviting affected companies to join as stakeholders.

Finally, Tim gave an outlook beyond EU on chemicals and product regulations that REACHLaw supports compliance with in Ukraine, UK, Türkiye, South Korea and India. A lot of work is currently on-going in India for BIS Certification (including for steel and metal products) and in Ukraine, as the pre-registration window under Ukraine REACH is now open and will be closing soon.

Tim concluded that the EU and global chemicals regulatory framework has never been more complex, fluid and thus requires a solid monitoring and impact assessment by companies.

Material Compliance: Implementation into company processes (VIA Consult, Olpe)

VIA Consult, a management consulting company for small and medium-sized business from South Westphalia/Germany, provided an overview of requirements in the area of Material Compliance with a focus on the automotive industry and how to integrate it into company processes. The presenters stressed that Material Compliance includes both legal requirements (in EU and globally) and all other requirements of customers. As a result of the increasing propagation and changing nature of environmental regulations and customer demands, the integration of Material Compliance into company processes (sales, purchasing, product development, production, etc.) is essential.

Implementation of Material Compliance in a company (KION Group, Frankfurt am Main)

Dr. Sebastian Müller, Director Environmental Product Requirements at KION Group, the biggest manufacturer of forklift trucks and warehouse handling equipment in Europe, and one of the world’s leading warehouse automation providers with ~42,000 employees globally, showed a selection of the growing number of Environmental Product Requirements (EPR) laws globally which are relevant for his group, and how they were introduced over time. He stressed the increasing importance of requirements related to electronics (RoHS), ESG and concerning the capital market. To address this complex environment for articles and complex objects, his company pursues a holistic approach, which is broken down into different EPR requirements and is underpinned by principles such as proportionality and a risk-based approach. An important starting point is the identification of applicable laws depending on the materials and legal entity. In relation to suppliers, a systematic IT-based EPR data management is implemented. The overall organisational setup is structured around an EPR Team which acts as the coordinators and owners of the EPR topic. Dr. Müller stressed that this is the best approach for his company, but it is not comparable to SMEs. How AI can be of help going forward is also currently explored. In conclusion, material compliance is seen and addressed as a mandatory business requirement, also with view to the pressure of the financial market.

Conclusions

Finally, Volker Bockskopf, Head of Environment and Occupational Safety, from the organiser WSM provided a presentation on letter templates (to answer customer requests etc.) vs. contractual anchoring specifically for his member companies. Overall, the seminar participants received a comprehensive roundup of the current chemicals regulatory landscape, key “hot topics” and how these legal and customer requirements can be addressed “on the ground” in companies.

References for further information  

India BIS Licence – Scheme X – REACHLaw
The Ecodesign for Sustainable Products Regulation – REACHLaw
Ukraine REACH and CLP – REACHLaw