The most significant revision plan for the EU's REACH regulation in nearly two decades (commonly known as REACH 2.0) has been postponed again. On November 3, 2025, the European Commission issued an internal planning document (SEC(2025) 2543), outlining potential agenda items for meetings from November 12, 2025, to January 28, 2026. However, the REACH revision was not included. This delay primarily stems from the negative opinion previously issued by the EU Regulatory Scrutiny Board (RSB) on the proposal’s impact assessment report, which highlighted significant unresolved issues in risk management, data integrity, and compliance costs.
Background
The REACH 2.0 revision aims to streamline processes, strengthen enforcement, and promote digitalization. Key reforms include:
- Registration System Overhaul: Setting a 10-year validity period for registrations, requiring re-submission of dossiers for substances of high concern, and mandating notification or registration of polymers based on tonnage.
- Enhanced Evaluation and Compliance: Granting the European Chemicals Agency (ECHA) the authority to revoke non-compliant registrations and prioritizing the evaluation of similar substances.
- Simplified Authorization Procedure: Introducing the concept of "essential use" and optimizing the use of the candidate list.
- Precision in Restriction Procedures: Improving risk prioritization and expanding the management of hazardous categories.
- Upgraded Enforcement and Market Surveillance: Introducing EU audit rights and strengthening customs controls and cross-border investigations.
- Advancement of Digital Supply Chains: Adopting electronic safety data sheets and digital product passports to reduce administrative burdens.
RSB's Negative Opinion
In September 2025, the RSB issued a negative opinion on the REACH 2.0 revision proposal, pointing to "significant unresolved risks to human health and the environment." The concerns primarily centered on three areas:
- Inadequate Health and Environmental Risk Management: Lack of critical hazard category information in chemical dossiers, incomplete usage and exposure data, insufficient handling of polymer risks, and failure of chemical safety assessments to cover all risks.
- Inefficient Regulatory Procedures: Slow adoption of new restriction regulations, lengthy authorization processes that fail to effectively promote alternatives, and inefficient decision-making processes.
- Compliance and Enforcement Gaps: Non-compliance of registration dossiers with REACH requirements, inconsistent enforcement efforts across member states, and concerns about the compliance of imported goods, particularly those sold online.
Due to the objections, the final REACH 2.0 proposal is now expected to be released in 2026. The negative opinion does not necessarily indicate major changes to the anticipated update plan. CIRS Group will continue to closely monitor the progress of REACH 2.0 and provide compliance assistance to enterprises.
