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If REACH were proposed today, many of the people who helped create it doubt Europe would find the political will to adopt it. That question now hangs over chemicals policy in 2026, as policy makers consider limited reforms of a law that once represented one of the EU’s most ambitious regulatory projects.
Twenty years ago, Europe rewrote the rules on chemicals. REACH survived fierce lobbying, dire warnings of economic damage and intense industry backlash. Today, despite stronger science, a mature regulator and two decades of experience, even limited changes to the legislation struggle to gain political traction.
Europe now finds itself in a very different political and economic landscape from the one that gave birth to REACH – an almost 850-page law accompanied by thousands of pages of guidance and implementing legislation.
REACH fundamentally reversed the burden of proof in chemicals regulation, requiring companies to demonstrate that their substances could be used safely rather than leaving regulators to prove harm after it had occurred.
The proposal sparked one of the biggest lobbying battles Brussels had ever seen, drawing opposition from both within the EU and abroad. Yet after six years of negotiations and some 5,000 amendments discussed in the European Parliament, REACH was adopted in 2006.
Today, policy makers who once debated sweeping reform now talk about reducing regulatory burdens with "simplification" and "targeted improvements" – concepts that have become central to the EU’s competitiveness agenda. They worry that reopening the text could unleash political battles they can no longer control.
The contrast raises a broader question: has Europe lost the political will that once made such an ambitious regulatory project possible?
Many of those who were involved in shaping the legislation argue that what is missing today is not just political ambition, but the sense of urgency that drove reform in the early 2000s.
REACH’s history is more than a retrospective exercise because today’s arguments over the regulation’s reform are, in many ways, versions of the same disputes that shaped the original law.
Debates over producer responsibility, registration quality, polymers, the use of restrictions and the balance between environmental ambition and industrial competitiveness all have roots in the compromises struck in the early 2000s. Understanding how those compromises were built – and what was left unresolved – helps explain why reform is proving so politically difficult now.
Once-in-a-generation opportunity
We had what they call a good tailwind … After 2000, there were six years where things were pretty stable
– Peter Smith
By the late 1990s, regulators knew remarkably little about many of the chemicals on the European market. Authorities carried the burden of proving risks, yet lacked the data needed to do so. Out of 30,000 individual chemical substances sold above one tonne per year, only 119 had finalised risk assessments, according to Robert Donkers, the then acting head of the chemical substances unit in DG Environment (DG ENV) and one of the architects of the European Commission's white paper and the REACH Regulation.
Donkers remembers mounting concern over chemicals in consumer products, from leaking phthalates in children's toys, anti-fouling substances in nappies to brominated flame retardants (BFRs) used in electronics and furniture, alongside persistent concerns that industry's "responsible care" and product stewardship commitments were not delivering the information regulators needed.
"It was a complete failure," recalls Thomas Jakl, who represented Austria in the negotiations. NGOs warned that, at the prevailing pace, it could take centuries to assess all existing chemicals, while new concerns about endocrine disruptors and other hazards were emerging faster than regulators could respond.
If the financial crisis had happened before 2008, it would have been much more difficult to adopt REACH
– Geert Dancet
The momentum for change coincided with a period of economic growth and a stable political climate that enabled far-reaching regulatory reform.
"We had what they call a good tailwind," recalls Peter Smith, who was then at Procter & Gamble and did extensive work mapping downstream users. Dr Smith later became Cefic’s director of product stewardship. "After 2000, there were six years where things were pretty stable."
Geert Dancet, then head of the Commission’s industry directorate and later ECHA’s first executive director, said governments were more willing than they are today to absorb the political risks of major regulatory change, despite concerns that registration requirements could undermine competitiveness.
"If the financial crisis had happened before 2008, it would have been much more difficult to adopt REACH," Dancet said.
Yet even in those favourable conditions, approval was far from assured. One of the biggest obstacles came from Germany, whose support was essential if the legislation was to survive.
At the time, the country was governed by a coalition of Social Democrats and Greens, with Jürgen Trittin serving as environment minister. German Chemical Industry Association (VCI) was among the most vocal critics of the proposal, backing studies that warned of major job losses.
According to Uwe Lahl, then an adviser to Trittin, the challenge was to reconcile the government's environmental ambitions with the concerns of Germany's powerful chemicals industry.
To break the deadlock, a high-level working group brought together government officials, trade unions and industry representatives to forge a compromise. The resulting agreement helped secure German backing, but only after concessions had been made. One of the most significant was the decision to exclude polymers from registration requirements – a compromise that Dr Lahl believes was crucial to keeping the project alive.
Looking back, key figures from that time describe REACH as the product of an unusually favourable convergence of political will, public concern and economic confidence – conditions that would become harder to find in the years that followed.
The impact of REACH
Twenty years on, one of REACH's clearest achievements is the vast expansion of information available on the chemicals market.
More than 23,000 substances have been registered under the system, creating an unprecedented body of information on the properties and uses of industrial chemicals. More fundamentally, REACH established the institutional infrastructure needed to manage that information.
For Dancet, one of REACH’s most enduring legacies is ECHA itself. Established in 2007, through a massive institutional effort during the law’s early implementation, the agency has grown into a scientific powerhouse with hundreds of staff and now sits at the heart of one of the world’s most sophisticated chemical regulatory systems.
The legislation has also become far more accepted than many of its architects expected. During the negotiations, Germany's chemicals industry fought hard to stop the proposal. Now the VCI says that REACH should largely be preserved and warns against reopening the text.
"It's ironic," Dr Lahl says. "Today, they say REACH is okay and should not be changed."
Some of REACH's effects are harder to measure. Michael Warhurst, who led Friends of the Earth’s work on EU chemicals policy until 2002 and then the World Wide Fund for Nature (WWF)’s until the end of 2004, points to hazardous substances that were quietly withdrawn from development or never commercialised because companies anticipated future regulatory scrutiny.
REACH changed the informational landscape, but not industry behaviour … It's like being caught without a ticket on a train and being told you can just buy one afterwards
– Michael Warhurst
"You only hear about the loudest producers, not the companies that quietly adapted," said Dr Warhust, currently executive director of NGO CHEM Trust.
Yet many of those who helped shape REACH argue that the legislation fell short of some of its original ambitions, particularly in making industry fully responsible for chemical safety.
"REACH changed the informational landscape, but not industry behaviour," said Dr Warhurst.
One consequence was persistent weaknesses in registration dossiers. A decision to allow companies to correct inadequate dossiers rather than treating them as failures weakened incentives to provide high-quality data from the outset.
"It's like being caught without a ticket on a train and being told you can just buy one afterwards," Dr Warhurst said.
An ECHA report in June covering the period from 2021 to 2025 found that 54% of active registration dossiers had not been updated during those five years, while 16% had not been updated for at least a decade. Weaknesses in registration data have, in turn, complicated restrictions and other regulatory processes that depend on strong scientific evidence.
Why reform is so hard
If REACH's adoption was a political triumph, its future is proving more complicated.
Experience with REACH has exposed weaknesses in the system and generated a host of ideas for improvement. But there is little agreement on how far reforms should go or how they should be implemented.
Concerns about industrial competitiveness, energy prices and geopolitical tensions have made the prospect of reopening the legislation politically fraught, with chemicals policy now bound up in wider debates about Europe's economic future.
Across Europe, right-wing populist parties have gained influence, making it harder to build broad coalitions behind major regulatory reforms. Once proposals reach the legislative stage, the Commission loses much of its ability to shape the outcome, leaving them vulnerable to lobbying, political bargaining and interventions from member states and MEPs.
Dancet also points to obstacles within the Commission, where responsibility for chemicals policy is split between DG ENV and DG GROW, whose priorities do not always align. He argues the Commission itself needs to become more efficient in managing the legislation, and that will require institutional change.
"Only one service should be responsible for the legislation, and I have no preference which one," Dancet said. "Maybe you start with one, and after five or ten years you move to the other."
Not if, but when
REACH has identified more than 250 SVHCs, yet only a quarter have progressed to the authorisation list – a mechanism designed to phase out the most hazardous chemicals unless companies can justify their continued use. Many endocrine disruptors and other SVHCs remain on the market, while longstanding challenges, such as polymers and chemical mixtures, and emerging concerns over persistent and mobile substances, have yet to be fully addressed.
Yet few believe this is the right moment to reopen the legislation, risking an unpredictable outcome.
I'm not sure what the price of a compromise will be. But the opening of REACH will come. Everyone should be prepared for it
– Uwe Lahl
Much can still be achieved within the existing framework. For Dr Warhurst, stronger producer responsibility remains unfinished business. He also argues that existing regulatory tools could be used more effectively to accelerate decision-making and focus resources on the substances of greatest concern.
In that regard, he sees ECHA's Assessment of Regulatory Needs (ARN) programme as one of the most significant developments of recent years, helping identify regulatory priorities across broader groups of substances and close important information gaps.
A greater reliance on restrictions rather than authorisation may be one way forward, although that raises questions about shifting the burden of proof back to authorities.
At the same time, most of those interviewed see reopening REACH as a question of when, not if.
Dr Smith argues that the debate itself may need to be reframed. Rather than cataloguing every chemical used in Europe and deciding which to regulate, regulators could start with environmental outcomes to determine which substances require tighter controls.
For Dancet, the longer-term challenge is broader. European chemicals legislation has developed over decades, creating inconsistencies across roughly 50 separate regimes adopted at different times. For example, substances restricted under REACH may also be covered under worker protection rules, while different pieces of legislation can apply different definitions and assessment criteria to hazardous chemicals.
Addressing those contradictions may eventually require a new white paper, Dancet says, when economic conditions permit.
Twenty years after its adoption, REACH therefore finds itself in a familiar position. As in the early 2000s, progress may depend less on finding a perfect solution than on building a political compromise that enough people can accept.
For industry, one element of that compromise may be greater clarity around concepts such as "zero pollution" and a "non-toxic environment", which underpin parts of EU chemicals policy but remain open to widely differing interpretations.
Dr Lahl argues that key stakeholder groups should begin informal discussions long before any formal proposal emerges.
"I'm not sure what the price of a compromise will be. But the opening of REACH will come. Everyone should be prepared for it," he says.