In April, 2025, during a CARACAL (Competent Authorities for REACH and CLP) meeting, the European Commission introduced new amendment proposals to the REACH Regulation. The proposals were immediately met with sharp criticism from key industry groups: the European Chemical Industry Council (Cefic), the European Federation of Construction Chemicals (EFCC), and the International Fragrance Association (IFRA). These associations argue the revisions conflict with the EU’s goals of promoting industrial competitiveness and warn of disproportionate impacts on small and medium-sized enterprises (SMEs).

Key REACH Revision Proposals

• Registration validity set at 10 years, with the European Chemicals Agency (ECHA) empowered to revoke non-compliant or outdated dossiers.
  

• Mandatory dossier updates when substances are classified as SVHCs or receive harmonized classification.
  

• Digitalization of supply chain communication, including digital safety data sheets aligned with Digital Product Passports (DPPs).
  

• Centralized EU authority to standardize national enforcement systems and conduct audits.
  

• Proposed deletions of Annexes III and XIII, and updates to Annexes I, VI–X, and XI.
  

• Introduction of Mixture Allocation Factors (MAFs) to assess cumulative chemical exposure.
  

• Clarification of Generic Risk Approach (GRA) tools.
  
  

Cefic: Disconnect from Industrial Reality

Representing 30,000 enterprises across 29 countries, Cefic criticized the proposed changes as “disconnected from real-world operations.” It emphasized that the EU chemical industry contributes €564 billion annually and employs 1.17 million people. Cefic warned that the revisions, especially the re-registration burden and increased compliance complexity, risk undermining competitiveness—particularly for SMEs. The association noted that the proposal closely resembles a version previously rejected by industry, indicating that prior feedback has been disregarded.

EFCC: Structural Risks and Burdens for SMEs

While EFCC supports digitalization, it flagged serious issues with several provisions:

• Polymer Registration: Mandated polymer registration could impose excessive financial and administrative demands, despite the relatively low risk of polymers compared to monomers.
  

• 10-Year Registration Validity: The finite validity period would force repeat submissions, straining company resources.
  

• MAF Impact: Applying MAFs broadly could unfairly penalize formulators, with minimal safety gains.
  

• GRA Concerns: EFCC emphasized the need to differentiate between professional and consumer use, arguing that workplace safety measures already mitigate risks.
  
  

The EFCC also called for publication of full impact assessments, including the competitiveness effects and strategies for reducing administrative burdens.

IFRA: Implementation Complexity for Fragrance Sector

IFRA focused on the practical challenges for SMEs and producers of natural extracts:

• Tonnage Threshold Flexibility: Suggested using a three-year average to determine registration thresholds, offering predictability.
  

• 10-Year Validity Issues: Deemed the expiration rule redundant and burdensome, especially since many registrations remain under review.
  

• Test Proposal Expansion: Argued that broader testing requirements conflict with simplification goals and burden SMEs reliant on small-batch inputs.
  

• Compliance Checks: Called for transparency in ECHA’s processes and alignment with CLP/CLH timelines.
  

• Stakeholder Engagement: Requested structured dialogue with authorities during assessments to ensure industry voices are heard.
  
  

IFRA’s Technical Concerns

• Enhancements to IUCLID to prioritize quality checks and reduce redundancies.
  

• Streamlined dossier preparation, avoiding repeated data inputs and slow synchronization between Chemical Safety Reports and IUCLID.
  

• Proposals for dropdown-based declarations and simplified inquiry processes to improve update efficiency.
  
  

Next Steps

The European Commission has not yet responded publicly. As the REACH revision process progresses, this growing rift between regulators and industry could significantly influence the future of EU chemicals policy and industrial competitiveness.

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