By the end of November 2025, the European Chemicals Agency (ECHA) officially announced the Forum Work Programme 2026-2027 (hereinafter referred to as the "Plan"). The Plan aims to enhance compliance levels across the entire supply chain, ensuring the safe use of chemicals and market fairness through strengthened import controls, online sales supervision, and comprehensive enforcement collaboration.
Priority Enforcement Areas
1. Import Controls
Results from previous enforcement projects indicate a consistently high non-compliance rate among imported mixtures and articles with chemical regulations. Data show that non-compliance rates for imported products range from 17% (under REACH restrictions) to 64% (under CLP labeling requirements). A recent EU-wide project (REF-12) focusing on registration, authorization, and restrictions at the import stage found that 32% of imported mixtures lacked registration information, while 7% of individually imported substances had missing registrations. In checks enforcing REACH restrictions, 16% of imported products failed to comply.
2. Online Sales
Low compliance rates in the online sale of chemicals and related articles are a widely recognized issue. An earlier forum project targeting online sales based on risk management revealed that over three-quarters of inspected products or sales listings violated regulations. Specifically, 78% of the sales listings inspected under REACH restrictions were non-compliant. The new CLP regulation and related horizontal legislation impose stricter requirements for online sales. Coupled with anticipated amendments to REACH, these changes will bolster chemical enforcement in this area. The Forum will continue leveraging these new regulations, building on prior experience to prioritize online sales control and harmonize enforcement approaches—including applying provisions from horizontal legislation such as the Digital Services Act and the General Product Safety Regulation concerning distance selling and online platforms. The results of the REF-13 online sales project, scheduled for release in 2026, will offer fresh insights into compliance levels and guide follow-up actions.
3. Integrated Enforcement
Due to the fragmented nature of chemical regulatory frameworks, the same substance, mixture, or article is often subject to multiple regulations. This is particularly evident in widely used materials such as soft plastics and textiles. For instance, certain articles may simultaneously fall under restrictions from REACH, the POPs Regulation, the Biocidal Products Regulation, the Waste Framework Directive, the Toy Directive, and the RoHS Directive. Given limited enforcement resources, integrating multi-regulation compliance checks where feasible—drawing on lessons from the Forum’s REF-10 project—can improve efficiency.
4. Strengthened Collaboration
Compliance improvements cannot be achieved by chemical inspectors alone; enhanced collaboration with peers and partners at multiple levels is essential. This multidimensional priority includes: strengthening cooperation with authorities overseeing related regulations, deepening collaboration between ECHA and national enforcement bodies, and enhancing ties with other regulatory networks.
Specific Enforcement Actions
1. Enforcement of Risk Management Measures
Previous enforcement projects have revealed high rates of non-compliance with REACH restrictions, authorization requirements, and CLH (harmonized classification and labeling). Given that these measures are designed to control substances of concern, compliance levels must be raised. The Forum will prioritize enforcement related to REACH restrictions and authorizations, CLP harmonized classification and labeling (CLH), and POPs restrictions.
2. Labeling Enforcement
A Forum project on the classification and labeling of mixtures found that 44% of mixtures failed to meet CLP obligations—17% had incorrect classifications and 33% had labeling errors. With many revised CLP obligations set to apply in 2026, the Forum will take prioritized action through the REF-14 project to harmonize enforcement of these fundamental requirements.
3. Enforcement of New Provisions
The Forum will also prioritize the harmonized enforcement of newly fully effective provisions. This includes new REACH and POPs restrictions coming into force in 2026 and 2027, as well as new CLP requirements such as classification based on new hazard categories, updated labeling rules, and obligations for online chemical sales.
Relevant companies exporting to the EU should conduct timely self-assessments and thoroughly evaluate product compliance under regulations such as REACH, CLP, and POPs to avoid supply chain disruptions or legal risks resulting from non-compliance.
Further Information
