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A leaked EU methodology for identifying "critical chemicals" would designate dozens of substances as strategically important to the bloc's industrial resilience, including ethylene, propylene, styrene, methanol, chlorine, hydrofluoric acid, titanium dioxide and polytetrafluoroethylene (PTFE).
The documents – including a report produced by Working Group 1 (WG1) of the Critical Chemicals Alliance (CCA) and seen by Chemical Watch News & Insight – contain the first detailed methodology for assessing chemical criticality, along with a non-exhaustive list of molecules that would qualify as critical under the proposed framework.
The documents give an early signal of which chemicals could receive EU-level protection, funding or permitting support, and which supply chains may face closer monitoring.
Companies using or producing listed substances may need to assess whether critical status for certain substances could reshape investment decisions, sourcing strategies and regulatory engagement.
Proposed chemicals
As part of a testing exercise, WG1 identified a broad range of chemicals that might meet the proposed criteria for criticality (see box).
The list includes many of Europe's key petrochemical building blocks, including:
- ethylene;
- propylene;
- butadiene;
- benzene;
- toluene;
- xylene;
- styrene;
- methanol;
- phenol;
- ammonia;
- chlorine;
- caustic soda;
- sodium carbonate; and
- hydrofluoric acid.
Also identified as critical are:
- titanium dioxide (TiO2);
- PTFE;
- polyvinyl chloride (PVC);
- polyethylene terephthalate (PET);
- silicones;
- acrylic acid;
- acrylate esters;
- ethylene oxide;
- propylene oxide;
- epichlorohydrin;
- vitamins B1, B6, B9 and D;
- methionine and lysine; and
- bio-based chemicals such as polylactic acid (PLA).
Molecules previously identified as strategically important by eight member states in a 2025 joint declaration would also qualify as critical under the proposed methodology, according to WG1.
The report describes the list as non-exhaustive and stresses that molecules not yet assessed could also be classified as critical in the future.
How chemicals qualify
Under the proposed framework included in the documents, molecules must pass three filters covering vulnerability and essentiality.
Criteria include import dependency, transport and storage constraints, competitiveness pressures, loss of European production capacity and importance to strategic sectors such as healthcare, defence, semiconductors, clean technologies and agriculture.
The methodology is designed to identify chemicals Europe should "retain or secure" because of their contribution to strategic autonomy, economic security and industrial resilience.
Substitutability criterion removed
A significant finding in the leaked papers is that WG1 considered, but ultimately removed, a criterion intended to assess whether chemicals have viable alternatives.
According to the report, members developed a dedicated criterion based on the substitution index used under the EU's critical raw materials framework. However, no member was willing to test the criterion because of concerns about its workability, and it was subsequently removed from the latest methodology.
The report nevertheless states that substitutability remains "a key dimension of essentiality" and says a dedicated criterion could be reintroduced in future revisions of the framework.
Notably, the proposed criterion on alternatives was not designed to assess whether hazardous chemicals could be replaced with safer or more sustainable substitutes. Instead, it focused on whether a molecule could be substituted while maintaining quality, performance, safety and regulatory requirements in downstream applications.
The report also treats sustainability separately through a dedicated "innovative special track" designed to identify molecules linked to areas such as biotechnology, recycling, renewable carbon, carbon capture and low-carbon production processes, rather than through the core criticality assessment itself.
As a result, the proposed methodology assesses whether chemicals are strategically important and difficult to replace from an industrial and value-chain perspective, but it does not include a formal assessment of whether they could be replaced by safer or more sustainable alternatives.
Support measures proposed
The leaked documents also provide the clearest picture yet of what critical status could mean in practice.
Alongside the methodology, WG1 recommends a package of measures aimed at protecting and supporting the production of critical chemicals and the sites that manufacture them.
These include:
- priority treatment in anti-dumping and anti-subsidy investigations;
- EU monitoring of supply risks for critical chemicals and value chains;
- dedicated state-aid support and funding mechanisms;
- energy-cost relief and Emissions Trading System (ETS) adjustments;
- accelerated permitting procedures; and
- "Buy European" measures intended to stimulate demand for EU-produced chemicals.
WG1 also recommends that once designated, a critical molecule should keep that status for at least eight years, even if later assessments suggest it no longer meets the criteria. The report says this would provide investment certainty and align with trade protection measures.
Hazard left out
The proposed methodology contains no dedicated assessment of hazard, toxicity, persistence, bioaccumulation, REACH status or CLP classification.
That broadly reflects positions previously outlined by both the European Commission and industry participants, who have argued that criticality should be assessed separately from chemicals risk management and that hazardous substances can still be strategically important under controlled conditions.
However, the omission is likely to intensify debate over whether criticality should be determined solely through industrial resilience and competitiveness criteria or also take into account broader chemicals-policy objectives.