MTE would like to share for your information the ECHA 2025-2027 work program that was released on 29 January 2025, which contains an overview of topics it will focus on and the respective resources it will require to carry out these tasks (link).
For our work, below are a few interesting points to note:
- Topics:
- REACH and CLP
- These two pieces of legislation will remain the largest workload for ECHA.
- With the new hazard classes adopted under CLP, ECHA expects an increase in proposals from the Commission and Member States for ECHA to evaluate.
Other (existing) topics:
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- PIC – ECHA supports the processing of information on the export and import of hazardous chemicals, provides support to companies and designated national authorities (DNAs) from both the EU and third countries, and supports the Commission with the implementation of the Convention
- POPs – ECHA facilitates the reporting obligations on behalf of the Member State competent authorities and compiles the EU overview of the implementation. ECHA also coordinates the enforcement activities via the Forum for Exchange of Information on Enforcement (Forum) and supports the Commission with the implementation of the Convention.
- Waste Framework Directive – SCIP database maintenance.
- Drinking Water Directive – ECHA is setting up and maintaining the European positive lists of substances that are authorised to be used for the manufacturing of materials coming into contact with drinking water.
- Batteries Regulation – ECHA will continue to support the Commission in identifying substances of concern found in batteries or used in their manufacturing. The Commission may request ECHA to prepare proposals to restrict hazardous substances in batteries and waste batteries and to adopt an opinion (through RAC and SEAC) on restriction proposals.
- Water protection: amendments to several Directives related to water protection, Water Framework, Groundwater and Environmental Quality Standards (EQS) Directives, are being discussed in the Ordinary Legislative Procedure and in the proposed changes, ECHA has been assigned new tasks, including the development of watch lists for surface and ground water, and development of Priority Lists, EU-wide EQS and indicative concentrations and ground water thresholds, and establish and disseminate a repository of national EQS values.
- Industrial Emissions Directive – ECHA is foreseen to input its knowledge on chemical uses, hazards and regulatory status into the revision and development of Best Available Technique Reference (BREF) documents, according to the relevant workplans developed by the European Integrated Pollution Prevention and Control Bureau (EIPPCB). In addition, ECHA has been tasked with the further development of a Chemical Management System (CMS), to be updated and applied as agreed with IED stakeholders in the context of the IED Forum.
- Others: End-of-Life-Vehicle (ELV) Directive revision & Toys Safety Regulation.
- New topics:
- Overall, ECHA recognizes it will need relevant areas of competence development including the new hazard classes in CLP as well as sustainability, life cycle analysis, and waste aspects particularly relevant for new tasks under RoHS, batteries etc.
- Specifically, new topics, due to the anticipated OSOA tasks:
- MDR à updating the phthalate guidelines à no new staff foreseen for this task
- RoHS Directive à 0 new posts foreseen for 2025, 7 new posts foreseen for 2026
- Common Data Platform à 0 new posts foreseen for 2025, 19 new posts foreseen for 2026
- Packaging and Packaging Waste Directive (PPWR) – ECHA will support the European Commission in identifying substances of concern found in packaging and packaging waste. The Commission may request ECHA to prepare proposals to restrict hazardous substances in packaging and packaging waste.
- Resources/Budget:
- ECHA recognizes that the regulatory landscape is becoming more complicated, due to the grouping of substances, new CLP hazard classes, waste and water topics etc. and this requires a lot of (new) resources for the Committees.
- The report makes a breakdown of revenue streams and expected expenditures, however, there are uncertainties due to the new topics ECHA will cover and what that will really require in terms of budget and human resources.
- A negative prioritisation/decrease in existing tasks is foreseen for:
- SCIP database maintenance.
- Reduced intensity in activities under identification and prioritisation of substances due to the milestones already achieved (in screening high volume substances) and new objectives set for Integrated Regulatory Strategy.
- Decreased number of opinions that can be delivered on authorisation applications due to limited committee capacity and increased restrictions activity.
- Next steps:
- Whilst this is a work program, the actual functioning of ECHA, resources, and funding, need to be regulated in the pending ECHA Founding Regulation (‘Basic Regulation’).
- The report explains that it was prepared in 2024 and that ECHA anticipates proposals for a revised REACH Regulation and an ECHA Basic Regulation from the Commission in the “coming period”.
- ECHA recognises that they need to engage with other EU Agencies – EFSA, EMA, ECDC and EEA, including to implement the OSOA and the One Health Joint Framework for Action.
