The European Commission has fallen far short of its 2022 pledge to regulate 22 high-risk chemical groups, including PFAS, bisphenols, PVC, and flame retardants, according to a new compliance report by ClientEarth and the European Environmental Bureau (EEB). Only six chemical groups have been regulated so far, raising concerns among overseas chemical buyers about supply-chain uncertainty and delayed compliance timelines.
Regulatory gap and timeline failures
The report reveals that out of the 22 chemical groups listed in the EU's 2022 roadmap, only six have actually been regulated. One group has only a declared intention to regulate, and one proposal is under ECHA consultation. The remaining 14 groups face an uncertain future: seven are stalled at the draft or REACH committee approval stage, and seven have not even begun the regulatory process.
Systemic delays and their impact
Under REACH rules, the European Commission must prepare a draft restriction within three months after ECHA's final opinion, but it has never met this deadline. Average delays are two years, with some cases stretching to 47 months. Examples include lead in ammunition and fishing weights, lead in PVC, certain flame retardants, and medium-chain chlorinated paraffins. During 167 months of cumulative delays, an estimated 98,355 tonnes of pollution occurred, with lead from ammunition and fishing gear accounting for about 44,000 tonnes per year.
PFAS regulation progress and concerns
PFAS, a group of over 10,000 persistent chemicals linked to cancer, reproductive toxicity, and hormone disruption, only saw a draft socio-economic analysis released in March 2026. The report estimates that full PFAS regulation could reduce environmental emissions by about 70,000 tonnes annually, or up to 76% under the original proposal. However, environmental groups worry that the scope of PFAS restrictions has already been narrowed, excluding industrial uses, personal protective equipment, and some medical devices without sufficient justification.
What buyers should watch
Overseas chemical importers and formulators should monitor the EU's slow regulatory pace, as it creates both risks and opportunities. Delays mean continued availability of certain substances, but eventual restrictions could be sudden or include unexpected exemptions. Companies using PFAS, bisphenols, PVC additives, or flame retardants should prepare for phased bans and consider alternative chemistries. The EU's group-based approach aims to prevent substitution with similar unregulated chemicals, so early compliance planning is advisable.
China sourcing context
For Chinese chemical manufacturers and exporters, the EU's regulatory delays offer a temporary reprieve but not a long-term solution. Products containing PFAS or other targeted groups may still face market access challenges in Europe, especially as individual member states like France move ahead with national bans. Exporters should track ECHA consultations and REACH committee decisions closely, as sudden regulatory acceleration could disrupt supply chains. Proactive substitution and documentation of compliance readiness will be key to maintaining EU market access.
Source: Read the original report | Published: April 27, 2026