By late November 2025, the European Chemicals Agency (ECHA) released the Forum Work Programme for 2026–2027 (hereafter “the Plan”). The Plan aims to improve compliance across the entire supply chain by strengthening import controls, enhancing oversight of online sales, and advancing coordinated enforcement to ensure the safe use of chemicals and fair market conditions.
Priority Enforcement Areas
1. Import Controls
Findings from previous enforcement projects continue to show high non-compliance rates for imported mixtures and articles. Non-compliance ranges from 17% under REACH restrictions to 64% under CLP labeling requirements.
In the REF-12 project, which examined registration, authorization, and restriction obligations at the import stage:
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32% of imported mixtures lacked required registration information.
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7% of imported individual substances were missing registrations.
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16% of checked imported products did not meet REACH restriction requirements.
2. Online Sales
Low compliance in online chemical sales remains a persistent challenge. A previous risk-based forum project showed that over 75% of inspected products or listings were non-compliant. Notably:
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78% of listings assessed under REACH restrictions did not meet requirements.
With new CLP obligations and horizontal legislation—such as the Digital Services Act and the General Product Safety Regulation—online chemical sales will face tighter enforcement.
The Forum will continue focusing on harmonizing online sales controls. Results of the REF-13 online sales project, expected in 2026, will provide updated compliance data and guide next steps.
3. Integrated Enforcement
Because chemical regulations are fragmented, many products—especially soft plastics and textiles—fall under several laws at the same time (e.g., REACH, POPs, BPR, Waste Framework Directive, Toy Directive, RoHS).
With limited enforcement capacity, combining checks across multiple regulations—following lessons from REF-10—will help improve efficiency.
4. Strengthened Collaboration
Improving compliance requires cooperation beyond chemical inspectors. This priority area focuses on:
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Strengthening links with authorities enforcing related legislation,
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Deepening collaboration between ECHA and national enforcement bodies, and
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Enhancing connections with other regulatory networks
Specific Enforcement Actions
1. Enforcement of Risk Management Measures
Past projects revealed high non-compliance with REACH restrictions, authorization obligations, and CLH classifications. Since these measures target substances of concern, improving compliance is a priority.
The Forum will focus on enforcement of:
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REACH restrictions and authorizations,
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CLP harmonized classification and labeling (CLH), and
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POPs restrictions.
2. Labeling Enforcement
A forum project found that 44% of mixtures failed to comply with CLP classification and labeling rules—17% due to incorrect classification and 33% due to labeling errors.
With many updated CLP obligations taking effect in 2026, the Forum will prioritize harmonized enforcement through the REF-14 project.
3. Enforcement of New Requirements
The Plan also emphasizes consistent enforcement of upcoming fully effective rules, including:
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New REACH and POPs restrictions entering into force in 2026–2027,
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New CLP hazard classes, updated labeling rules, and
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Online sales obligations for chemicals.
Compliance Recommendations for Companies
Businesses exporting to the EU should proactively conduct self-assessments and thoroughly evaluate product compliance under REACH, CLP, POPs, and related legislation. Early preparation will help avoid supply chain disruptions, enforcement actions, or legal risks arising from non-compliance.
