MedTech Europe would like to share with you a summary of the European Parliament’s recently published ‘Targeted scrutiny of the EU chemicals strategy for sustainability’.
Background
The EU chemicals strategy for sustainability (CSS), introduced in 2020 as part of the European Green Deal, sets out 85 actions to curb chemical pollution, safeguard human and environmental health, and boost innovation and competitiveness in the chemicals sector. In June 2025, the European Parliamentary Research Service published a progress report on the implementation of the CSS.
Main findings of the report
The report identifies three key achievements under the CSS:
- Classification, Labelling and Packaging (CLP) Regulation: the regulation was reinforced – through its revision – to address challenges such as emerging health and environmental concerns, scientific findings requiring rapid response, and the need for coherence and predictability for all actors.
- Industrial Emission Directive (IED): the directive was revised to improve the management of hazardous chemicals through the formal involvement of ECHA in preparing Best Available Techniques (BAT) Reference Documents (BREFs), which are the basis for the permitting of industrial installations under the IED. In parallel, the Industrial Emissions Portal Regulation has streamlined the reporting and public accessibility of environmental data from industrial installations.
- One Substance One Assessment (OSOA) package: the package proposed by Commission in December 2023, seeks to harmonise the evaluation processes for chemical hazards and risks across various legislative frameworks, optimise governance between agencies, and enhance stakeholder confidence in scientific evaluations. While this has been listed as an achievement, the report also notes that the OSOA package misses strengthening the governance of ECHA and increasing the sustainability of its financing model.
The report continues by identifying commitments listed under the Strategy that remain unfulfilled:
- REACH revision: in the CSS, the REACH revision proposal was announced by 2022 and then pushed forward and is now scheduled for late 2025. The revision of the REACH Regulation was supposed to be a central element of the Strategy, as 12 of its 85 actions refer to REACH.
- Export ban of hazardous chemicals: one of the key objectives of the CSS was to position the EU as a global leader in the responsible management of chemicals, including ensuring that hazardous chemicals banned in the EU are not produced for export. One possibility was to revise the Prior Informed Consent (PIC) Regulation; however progress on this revision stalled in 2023, leaving a significant gap in the EU’s CSS implementation.
Areas of ongoing development are also discussed as they are being addressed also in the new Commission’s mandate:
- PFAS action plan: while there are some achievements in this area ( proposal for a ban on PFAS in firefighting foams and the establishment of an EU-wide approach under R&I programmes to develop remediation methods and promote safe alternatives, other actions are still pending of have reduced ambition:
- The ‘universal PFAS’ restriction proposal
- Binding provisions to consider PFAS as a group are absent from the Commission proposals in water files (UWWTD, WFD and DWD)
- The scope of the new Industrial Emissions Portal Regulation, which includes only PFOA and PFOS.
- Competitiveness for the chemical industry: a core objective of the CSS. To this end, the Commission set up a High-Level Roundtable on the implementation of the CSS; however, while the roundtable was expected to meet twice a year, it only came together four times between May 2021 and January 2025, and no follow-up actions were identified in the meeting conclusions. Additionally, a new high-level forum – the strategic dialogue on the future of the chemical industry – was launched in 2025; however, its connection to the high level
roundtable remains unknown. The transition pathway for the chemicals industry published in 2023, lists 187 actions for the short, medium and long term organised around eight building blocks, particularly sustainable competitiveness, funding and regulation. According to the transition pathway’s first progress report published in May 2024, around 80 % of those actions needed for the twin transition have been launched. No further information on the pathway’s achievements or future exists.
- New initiatives and commitments under the 2024-2029 Commission mandate: The new Commission has already published two new flagship initiatives designed to respond to the need for a sustainable and competitive chemicals industry: the competitiveness compass and the Clean Industrial Deal. On these, the report highlights how they lack reference to existing strategies and to the commitment to improve human health and environmental protection and only refer to decarbonisation and circularity. The Commission has also pledged to release other initiatives: Action plan for the chemical sector (summer 2025), Sector-specific omnibus (summer 2025) and Chemical industry package (late 2025).
- REACH revision, tabled for 2025, should encompass the extension of GRA, the addition of PMT and vPvM substance to the SVHC list, introduction of MAF, simplification and improvement of authorisation and restriction processes, introduction of requirements for the registration of polymers, promotion of the use of NAMs and improvement of the enforcement of the REACH provisions.
Conclusion: current situation, challenges and future directions
The report highlights that the EU faces significant challenges in addressing chemical pollution, with ongoing threats to human health and the environment, especially from substances like PFAS, bisphenol A, and trifluoroacetic acid. Despite progress through initiatives like HBM4EU and PARC, harmful chemical use remains high, and exposure frequently exceeds safety thresholds. Regulatory gaps persist, particularly around the delayed REACH revision and limited action on PFAS, prompting scientists and health experts to call for stronger measures, such as the inclusion of mixture assessment factors. Meanwhile, new Commission initiatives risk creating confusion and redundancy, highlighting the urgent need for coherent, coordinated implementation of existing strategies and robust scrutiny of future actions.
The full report is available at the following link: Targeted scrutiny of the EU chemicals strategy for sustainability
