What is the REACH Revision?
Under the European Green Deal (2019) and the Chemicals Strategy for Sustainability “CSS” (2020) the European Commission aimed to revise the rules governing the Registration, Evaluation, Authorisation and Restriction of chemicals in the EU, as currently set out in Regulation (EC) No 1907/2006 (REACH), including through amendments of the core legal text. This REACH Revision aimed to further improve the protection of human health and the environment against hazardous chemicals and to encourage innovation to develop safe and sustainable alternatives.
Where are we now?
Following in-depth impact assessments and stakeholder consultations in 2021-2022 the REACH Revision proposal by the European Commission as envisaged in the CSS was delayed several times. On 27 April 2026 the European Environment Commissioner Jessika Roswall announced in the European Parliament that the Commission has decided to not open the REACH legal text at this point, as certainty and predictability are important.
Instead, the Commission focus is now on improving effectiveness within the current framework through simplification and modernisation measures adopted through comitology legislation (i.e. amending Annexes to REACH), alongside initiatives to foster enforcement.
Who is affected?
Within industry the REACH Revision – regardless of its extent – or else the adapted implementation of existing REACH requirements may affect all actors along the supply chains of substances, mixtures and articles placed on the EU/EEA market. This concerns in particular manufacturers, importers and downstream users of substances and mixtures, but also suppliers of articles and complex products.
Substances under the scope of the REACH Revision
There is no closed list of substances – on their own, in mixtures or in articles – that may be affected by possible future measures relating to the REACH Revision or else the adapted implementation of existing REACH requirements.
Priority substance groups and related possible measures include:
- Substances fulfilling new hazard classes according to the revised CLP Regulation, e.g. endocrine disruptors, could be subject to new information requirements for registration;
- PFAS (per- and polyfluoroalkyl substances), which are subject to an ongoing wide restriction proposal under EU REACH as a high-priority matter for the Commission;
- Various (other) groups of substances included in the REACH Restrictions Roadmap, e.g. bisphenols, Cr(VI) substances, flame retardants or siloxanes.
The Commission also aims to streamline and increase efficiency on REACH authorisation and restrictions through better upfront planning and prioritisation, including by early discussions in the One Substance One Assessment Expert Group and through the REACH Restrictions Roadmap.
Potential Obligations for EU REACH Registrants and downstream actors
Based on the current information, the REACH Revision through comitology or else the adapted implementation of existing REACH requirements could result in the following new duties:
- Update of registration dossiers to reflect enhanced information requirements / scrutiny
- Digital Safety Data Sheets (SDSs)
- Update SDSs and Exposure Scenarios
- Compliance with broader REACH restrictions, especially group-based (e.g. reporting)
- Response to stronger enforcement
Note that additional obligations may also arise from the parallel CLP Revision and the Ecodesign for Sustainable Products Regulation (ESPR, see more information here). In addition, complementary tools to REACH restrictions such as Occupational Safety and Health and Industrial Emissions legislation are foreseen to be better explored.
What about non-EU manufacturers/formulators?
Non-EU exporters to EU/EEA will remain in the same role as under the current REACH, i.e. they may choose to operate through Only Representatives within the scope of REACH Article 8 and otherwise have to support their EU customers’ (importers’) REACH compliance. It should be noted that according to the CSS the Commission aims to better target known areas of high risk of non-compliance, including imported articles and online sales (among others).
Are there any specific deadlines?
The timeline for REACH Revision activities through comitology is currently unknown. It is also expected that the implementation of new measures will be subject to certain transition periods; those are still to be elaborated. Substance-specific activities as part of the REACH restriction process (as well as other risk management processes) have to be followed on a case-by-case basis.
Impacts on businesses
The industry impact will largely depend on the type and extent of measures (incl. new obligations) to be proposed as well as the implementation by the European Commission, ECHA and the EU/EEA Member States. However, the number of new hazard classes to be addressed and the Commission’s on-going activities (such as the REACH Restrictions Roadmap) show that the impact is likely to be significant for the actors covered by it (e.g. planned “universal” PFAS restriction).
How to prepare?
Companies placing on the EU market substances, mixtures and articles containing SVHCs, (other) substances fulfilling new hazard classes according to the revised CLP and other substances targeted by regulatory risk management are advised to monitor the evolution of REACH-related requirements and assess the possible impacts of forthcoming changes for their products. This concerns especially products containing the substances listed above. Ongoing activities (e.g. REACH Restrictions Roadmap) should also be followed and input for ECHA public consultations be gathered.
REACHLaw Support
Our services bring together our regulatory expertise and your product know-how, guiding you through the various elements of the REACH Revision and helping you take the appropriate actions.
REACHLaw can support your preparations for the REACH Revision in various ways; our services include:
- REACH Revision impact / change analysis and monitoring
- Position development for Commission calls for feedback and ECHA public consultations
- Training / awareness raising for industry associations and upstream suppliers
- Consultancy (Regulatory, Technical, Legal)
Please let us know in case you are interested in our support, by sending an e-mail to tim.becker@reachlaw.fi.
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Last update of webpage contents in this section:
8 July 2026