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Ecotox REACH 2025 Conference: Key Takeaways on REACH 2.0, CLP Revision, and PFAS Restrictions

This blog was originally posted on 30th September, 2025. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY DIEUDONNE YMEDJI, SENIOR REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS

The Ecotox REACH 2025 Conference was held on September 22-23, 2025, in Katowice-Chorzów, Poland. It gathered a diverse range of stakeholders, including industry representatives, industry associations, academia, and regulatory bodies from the European Commission, the European Parliament, and the European Chemicals Agency, to discuss the significant changes upcoming in EU chemical and product safety regulations.

This blog offers an overview of key topics discussed, including the upcoming “REACH 2.0”, the revision of the CLP regulation as part of the “Omnibus VI” legislative package on chemicals, updates on the PFAS restrictions proposal, the interface between specific product regulations and the GPSR, along with compliance challenges and enforcement issues.

1. Upcoming REACH Revision

One of the main topics discussed was the upcoming revision of the REACH regulation, for which the final proposal is expected to be made public by the EU Commission by the end of 2025. This targeted revision aims to simplify the rules for the chemicals industry while ensuring that safety and environmental protection are not compromised. Presentations from the European Commission and the European Parliament confirmed that the planned revision will introduce significant reform relating to chemical registration.

These include:

A 10-year validity for chemical registrations and the empowerment of ECHA to revoke registrations due to expiration, failure to update, incomplete data, etc.
A shift to digital safety data sheets,
The introduction of a Mixture Assessment Factor (MAF) to account for combined chemical exposure for substances registered at >1000 t/y,
The streamlining of reporting obligations by implementing simplified templates and reducing disclosure frequencies, such as in the context of sustainability reporting for financial institutions,
The obligation to update the registration dossier if a substance is identified as an SVHC
Notification of polymers produced over 1 t/y and mandatory registration requirement for polymers identified as ‘Polymers requiring registration’ (PRR).

Other significant changes will include the:

Introduction of digital supply chain communication, such as digital safety data sheets and alignment with the DPP;
Adoption of the nanomaterial definition as agreed upon in the 2022 Commission Recommendation;
Simplification and clarification of the authorisation process;
Simplification of restrictions with extension of the generic management approach specifically for assessing hazardous substance uses in consumer products (i.e. shift from substance-specific to generic restrictions);
Simplification of the information requirements of substances in articles, and the
Strengthening of enforcement and market surveillance with measures reinforcing customs control, supporting national authorities to optimise enforcement systems.

Subsequent insights from the experts’ panel discussion revealed that the Commission’s proposed changes, while intended to simplify processes, have raised significant concerns among industry associations. These groups argue that the changes could significantly increase the administrative burden on SMEs, which often lack the resources to navigate complex compliance requirements. Moreover, these additional regulatory burdens may hinder innovation and growth, creating further challenges for businesses in an already challenging economic environment.

2. Alignment with Digital Transformation

Discussions on this topic highlighted a significant shift towards fully digitalising labelling requirements in specific product legislation, including cosmetic products and the updated detergents regulations. This transition closely aligns with the objectives of the European Digital Product Passport (DPP), which aims to foster greater transparency within the supply chain, enabling both consumers and industry stakeholders to access essential product information easily.

However, to fully embrace this digital evolution, companies will need to make substantial investments in upgrading their systems and processes. This includes developing robust infrastructures to handle and manage a wealth of digital compliance data, ensuring that all information is accurate, secure, and readily accessible.

3. PFAS Restrictions and Sector-Specific Revision Proposals

Regulatory trends regarding PFAS and updates to sector-specific rules were also discussed at the event. A dedicated presentation by an industry association provided insight into the revised proposal published by ECHA on 20 August 2025. The revised proposal incorporates over 5,600 stakeholder comments and reflects new scientific evidence gathered since the initial submission in 2023. He addressed the revised scope of the restrictions, noting the exceptions made for industrial sectors, the stricter controls imposed on consumer applications, and how these changes will require adaptation across various industries.

Additional detailed presentations explored the complex relationships among the revised Detergents Regulation, the Cosmetics Regulation, and the recently implemented General Product Safety Regulation (GPSR). They emphasised the critical need for customised compliance strategies tailored to the unique challenges posed by each regulation. Presenters underscored that a one-size-fits-all approach is no longer sufficient in navigating today’s multifaceted regulatory environment. Industry must now consider various factors, including the specific characteristics of their products, the stringent user safety requirements imposed by regulators, and the environmental impacts associated with their offerings. This holistic view is crucial for ensuring thorough compliance with the evolving regulatory standards.

4. CLP revision and the “Stop-the-Clock” Simplification Mechanism

Another key theme discussed was the EU’s aim to simplify chemical legislation, as detailed in the EU Action Plan for the Chemicals Industry, published in July 2025. The plan emphasises the need for more efficient and coherent regulations to enhance safety, sustainability, and innovation within the chemical sector, ultimately fostering a more competitive and environmentally friendly industry across Europe.

In this context, an expert panel reviewed the Commission’s proposed “stop-the-clock” mechanism related to procedures and requirements for chemical products. It is noteworthy that this proposal, part of the “Omnibus VI” package, was endorsed by the Council of the EU just a day after the conference concluded on 24 September. It delays the implementation of the revised CLP regulation’s mandatory formatting rules under Regulation 2024/2485 until 1 January 2028. It also modifies deadlines related to relabelling obligations, formatting requirements, advertising rules, distance selling provisions, and the labelling of fuel pumps.

The panel further emphasised the importance of this extension, which not only provides businesses with much-needed legal certainty but also aims to reduce confusion that could arise from overlapping application dates resulting from different amendments to the CLP regulation.

It also emerged that the decision to delay the revised CLP regulation is not an isolated action by the Commission; rather, it reflects a broader trend within the EU of postponing or scaling back ambitious regulations. This includes rules relating to supply chain due diligence, corporate sustainability reporting, and deforestation.Lastly, the participant was reminded that the “Stop the Clock” proposal is a temporary delay, not a cancellation of the revised measures regarding the labelling, classification, and communication of chemicals. These measures will still be implemented, but on a slightly extended timeline. Affected businesses should use this delay to invest in digital tools, reformulate their products to align with the new hazard classes, and ensure that their suppliers are prepared for digital Safety Data Sheets (SDSs).

5. Broader and Global Perspective on Chemical and Product Safety Regulations

The conference also highlighted the pressing nature of chemical management as a significant global concern affecting many industries and communities. To illustrate, an expert panel provided an update on the implementation of the Ukraine REACH, demonstrating the broader adoption of EU-like regulations.

Additionally, a presentation on South Korea’s product classification system engaged participants, emphasising its rigorous pre-market safety assessments for household chemicals. The subsequent discussions fostered an understanding of various regulatory frameworks and encouraged dialogue on best practices to enhance global chemical management efforts.

6. Chemical Control from an Inspector’s Perspective

The final session of the event aimed to deepen participants’ understanding of the regulatory landscape surrounding chemical control and enhance their compliance strategies. An inspector from the Polish enforcement authority discussed the following key points:

The importance of complying with REACH regulations and how compliance is assessed across industries,
Common challenges inspectors face, such as data verification difficulties, resource limitations, and complex supply chains,
Emerging trends and regulatory changes, including a focus on sustainability and digital tools for compliance monitoring,
Essential skills and knowledge needed by inspectors for effective enforcement of chemical regulations.

The inspector recommended best practices for chemical management, including maintaining proper documentation, conducting risk assessments, and keeping SDS up to date.

Additional engaging discussions underscored how inspectors prioritise SVHC during inspections and the implications for manufacturers and importers.

Lastly, sharing case studies of successful compliance provided practical insights for businesses to apply in their organisations to address potential compliance gaps proactively.

Conclusion

The insights shared during the conference will be invaluable for companies as they prepare for the regulatory shifts underscored during the event. Participants left with a clearer understanding of the evolving regulatory landscape and the potential impacts on their operations, from compliance to market strategies.

Overall, the conference not only highlighted the challenges and opportunities presented by regulatory changes but also reinforced the importance of collaboration and dialogue among all stakeholders, including regulators, industry leaders, and advocacy groups.

What Actions Can Businesses Take?

The document conveys several actionable messages for businesses regarding the evolving regulatory landscape in chemical and product safety. Here are the key takeaways:

Invest in Digital Tools: Businesses are encouraged to invest in upgrading their systems and processes to manage digital compliance data effectively. This includes aligning with the European Digital Product Passport (DPP) to enhance supply chain transparency and meet new digital labeling requirements.
Prepare for Regulatory Changes: Companies should proactively prepare for upcoming revisions to regulations, such as the revised CLP regulation and PFAS restrictions. This involves reformulating products to align with new hazard classes and ensuring that suppliers are ready for digital Safety Data Sheets (SDSs).
Leverage the “Stop-the-Clock” Mechanism: The temporary delay in the implementation of the revised CLP regulation provides businesses with a critical window to ensure compliance without immediate pressure. Companies should use this time to invest in necessary digital tools and refine their compliance strategies.
Enhance Compliance Strategies: Businesses should adopt best practices for chemical management, such as maintaining proper documentation, conducting risk assessments, and keeping SDSs up to date. This will help address potential compliance gaps and prepare for inspections.
Engage in Collaboration: The document emphasizes the importance of collaboration and dialogue among all stakeholders, including regulators, industry leaders, and advocacy groups. Businesses should actively engage in discussions to better understand regulatory changes and advocate for their interests.

By taking these actions, businesses can navigate the regulatory changes more effectively, reduce administrative burdens, and foster innovation while ensuring compliance with new requirements.

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