EU chemicals policy in flux: what to expect from Brussels

A critical year for chemical regulation, trade, and industry

From the long-awaited revision of the REACH regulation to rising pressure on PFAS and the global implications of trade tensions, 2025 is a pivotal year for the EU chemicals policy. For companies operating in this space, navigating the evolving regulatory landscape will require both agility and strategic foresight.

In this article, we explore the key developments on the horizon, highlighting what’s at stake and how businesses can prepare for the policy shifts that will redefine chemicals regulation in Europe.

 

REACH revision: long-delayed, highly anticipated

The EU’s flagship chemicals legislation, REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), is on the cusp of its most significant revision in over a decade. Originally promised under the 2020 Chemicals Strategy for Sustainability, the proposal has been repeatedly delayed due to political sensitivities and stakeholder disagreements.

Now, with a legislative draft expected in late 2025, the Commission is aiming to bring the regulation into the digital age while strengthening public health and environmental protections. The revision is expected to expand REACH’s scope to include substances like polymers and persistent, mobile, and toxic chemicals, and introduce more efficient tools for restricting harmful substances across entire product groups.

But the real fault lines lie in how far the revision will go. While there is broad consensus around modernisation and digitalisation of the EU chemicals policy, more ambitious proposals, such as a new approach to risk assessment and stricter authorisation requirements, are still being debated within the Commission itself, particularly between DG ENV and DG GROW.

 

PFAS under pressure: a phased approach, not a blanket ban

Per- and polyfluoroalkyl substances (PFAS), often dubbed “forever chemicals” due to their persistence in the environment, are under increasing regulatory scrutiny in the EU. But despite some headlines, the EU is not currently planning an outright ban. Instead, a phased restriction approach is being considered, with essential-use exemptions likely to be central to the final policy.

The European Chemicals Agency (ECHA) is currently evaluating a landmark proposal for a universal PFAS restriction, submitted by five member states: Denmark, Germany, the Netherlands, Norway, and Sweden. The process involves scientific reviews by both the Risk Assessment Committee (RAC) and the Socio-Economic Analysis Committee (SEAC). A final opinion is expected by late 2025 or early 2026, with the European Commission and Member States making the ultimate decision, likely leading to an enforceable restriction around 2026–2027.

The proposal is sector-specific, meaning some uses may be excluded from the EU chemicals policy entirely, such as PFAS in pesticides, while others could be granted time-limited exemptions, including in areas like firefighting equipment or medical devices. Notably, exemptions are being explored for essential applications such as asthma inhalers and semiconductor production, particularly where no viable alternatives currently exist.

The Commission has already moved ahead with targeted restrictions on subgroups of PFAS, such as PFHxA, which is now limited in consumer textiles, food packaging, and cosmetics where safer alternatives are available. Other PFAS like PFOS and PFOA are already restricted under the EU’s Persistent Organic Pollutants (POPs) Regulation and the international Stockholm Convention.

Adding to this momentum, some Member States, including France and Denmark, are advancing their own national restrictions on PFAS in specific products. This growing patchwork of regulation further underscores the need for businesses to adopt proactive phase-out strategies and keep a close watch on both EU-wide and national developments.

For companies reliant on PFAS in their products or processes, the message is clear: the transition is coming, and it’s not just a matter of if, but when—and how.

 

Simplification with strings attached

In parallel with more stringent controls, the Commission has pledged to reduce the administrative burden of the EU chemicals policy, particularly for small and medium-sized enterprises. This includes plans to simplify registration procedures, improve transparency through a new digital chemicals platform, and cut compliance-related red tape by up to 35% for SMEs.

While industry has welcomed the simplification narrative, not everyone is convinced. Civil society groups warn that new procedural steps, such as the proposed Regulatory Management Option Analysis (RMOA), could actually create more bureaucracy, not less. The challenge ahead will be finding the right balance between clarity, efficiency, and environmental ambition.

 

Global dynamics: chemicals and trade collide

Adding to the domestic regulatory agenda is the growing impact of international trade dynamics. Recent US tariffs targeting European chemical exports have reignited concerns over supply chain stability and the strategic vulnerabilities of Europe’s chemicals industry.

These developments underline the importance of aligning chemicals regulation with the EU’s broader goals on strategic autonomy, green industrial policy, and global competitiveness. Whether through trade, defense, enhanced enforcement of import rules, or stronger origin requirements, the chemicals sector is likely to remain at the centre of Brussels’ economic security agenda in 2025.

 

Looking ahead

For companies operating in or exporting to the EU, 2025 will be a year of strategic decisions. From staying ahead of REACH reforms and preparing for PFAS restrictions to managing new digital compliance systems and navigating transatlantic trade tensions, the ability to anticipate and adapt will be essential.

At Publyon, we help clients make sense of complex policy landscapes and build future-proof strategies. Whether you’re facing regulatory risk or looking to shape the debate, our team is here to support you through the green transition and beyond.

Want to stay ahead of the EU chemicals policy in 2025? Reach out to Publyon for tailored insights and guidance on EU regulation, sustainability, and compliance.