ROHS Compliance

On 12 December 2025, the Official Journal of the European Union published Regulation (EU) 2025/2455 establishing an EU Common Data Platform for Chemicals. The regulation requires the creation of a single, unified EU chemicals data platform by 2 January 2029. The platform will consolidate chemicals-related information across the EU in line with the FAIR principles—Findable, Accessible, Interoperable, and Reusable—and introduce chemical monitoring and early-warning systems to strengthen the protection of human health and the environment.

I. Background

The EU’s chemicals regulatory framework is highly fragmented, with data distributed across multiple agencies—such as ECHA, EFSA, EEA, EMA, EU-OSHA—and Member State authorities. This fragmentation has resulted in data duplication, inconsistent risk assessments, and limited public confidence. To improve the coherence and scientific robustness of chemical risk assessments, reduce administrative burden and animal testing, support the EU Green Deal and the objective of a toxic-free environment, and enhance transparency and public trust, the EU has decided to establish a unified chemicals data platform.

II. Establishment of the “Common Data Platform”

1. Responsible Authority The European Chemicals Agency (ECHA) will be responsible for developing, operating, and maintaining the platform.

2. Scope of Data

a) Legally Required Data Chemicals data generated or submitted under EU legislation listed in Annex I and held by ECHA, EEA, EFSA, EMA, EU-OSHA, or the European Commission.

b) Project and Research Data Chemicals data originating from EU, Member State, or international research and project activities, where such data are received by the above authorities.

c) Voluntarily Submitted Data Data voluntarily provided and accepted from Member States, third countries, research bodies, and other relevant stakeholders.

Excluded Data

· Detailed mixture composition information submitted under Article 45 of the CLP Regulation

· Information contained in Cosmetic Product Notifications (CPNP)

· Internal agency working or decision-making documents, unless explicitly specified

III. Dedicated Service Modules

· IPCHEM (Chemical Monitoring Data)

· Reference Values

· Study Notifications

· Regulatory Processes

· Chemicals in Articles and Products

· Alternatives to Substances of Concern

· Legal Obligations Finder

· Standard Formats and Controlled Vocabularies

· Environmental Sustainability Data

IV. Access Rights

User Type Access Rights

Public Free access to non-confidential data; downloadable and machine-readable.

Regulatory

Authorities Access to all data, including confidential data, for enforcement, assessment, and policy-making.

Businesses &

Third Parties No direct access to confidential data; can apply for access under Regulation (EC) No 1049/2001.

V. Timeline

Action Deadline

Implementation Plan (specifying datasets and rollout schedule) To be published by July 2, 2026

Platform Launch (all core datasets must be integrated) By January 2, 2029

Integration of Historical Data (data generated before 2026) To be completed by January 2, 2036

Study Notification Obligation (companies must register

commissioned studies) Effective from November 2, 2027

Human Biomonitoring Studies (EU-wide surveys on human

chemical exposure) To be launched by January 2, 2030

The regulation will automatically enter into force on 2 January 2026, i.e., 20 days after its publication in the Official Journal of the European Union. The creation of the Common Data Platform is expected to deliver significant benefits for businesses by greatly enhancing the accessibility, transparency, and efficiency of accessing chemicals-related data across EU regulatory frameworks.

Key EU regulations covered by the Common Data Platform include:

· Food Contact Materials (FCM): Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food

· REACH: Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals

· CLP: Regulation (EC) No 1272/2008 on the classification, labelling, and packaging of substances and mixtures

· Food Additives: Regulation (EC) No 1333/2008 on food additives

· Plant Protection Products: Regulation (EC) No 1107/2009 concerning the placing of plant protection products on the market

· Cosmetics: Regulation (EC) No 1223/2009 on cosmetic products

· Biocidal Products (BPR): Regulation (EU) No 528/2012 on the making available and use of biocidal products

· Fertilisers: Regulation (EU) 2019/1009 on EU fertilising products

· Fluorinated Greenhouse Gases (F-gases): Regulation (EU) 2024/573 on fluorinated greenhouse gases

· Toy Safety: Directive 2009/48/EC on the safety of toys

· WEEE: Directive 2012/19/EU on waste electrical and electronic equipment

· Batteries: Regulation (EU) 2023/1542 on batteries and waste batteries

This integrated approach is expected to streamline regulatory compliance, reduce duplication, and support more consistent chemical risk assessments across the EU.