The EU Green Deal's Chemical Strategy for Sustainability: What Has Been Retained and What Has Changed

When the European Commission introduced the Chemicals Strategy for Sustainability (CSS) in October 2020 as part of the European Green Deal, it outlined one of the most ambitious reform agendas for chemical regulation in decades. The strategy proposed changes ranging from revisions to REACH and stronger management of hazardous substances to the promotion of safe and sustainable-by-design chemicals and a more coordinated approach to chemical assessments.

Several years later, the regulatory picture is more nuanced. While many elements of the strategy continue to move forward, others have progressed more slowly or have been reshaped as the European Union balances sustainability objectives with industrial competitiveness. For procurement professionals supplying chemicals into the EU, understanding what has been implemented and what has changed is essential for effective compliance planning.

The Original Vision of the Chemicals Strategy for Sustainability

The Chemicals Strategy for Sustainability aimed to create a safer and more sustainable chemicals market while supporting innovation across European industry.

Among its principal objectives were:

• Stronger protection against the most harmful chemicals.

• Greater emphasis on endocrine disruptors and persistent substances.

• Expansion of safe and sustainable-by-design innovation.

• Improved coordination of chemical assessments across EU legislation.

• Modernization of the REACH regulatory framework.

Together, these initiatives sought to reduce regulatory fragmentation while encouraging the development of lower-risk chemical products.

What Has Been Implemented

Not every proposal remains at the planning stage. Several important parts of the CSS have progressed into practical implementation.

One of the most significant developments is the One Substance, One Assessment (OSOA) framework. The legislation supporting this initiative entered into force on 1 January 2026, creating a coordinated approach to chemical assessments across multiple areas of EU legislation while introducing a common chemicals data platform and stronger cooperation between EU agencies.

The European Commission has also continued expanding work on the safe and sustainable-by-design concept, supporting research and industrial transition toward chemicals with improved environmental and health profiles.

In parallel, regulatory work has continued on substances of very high concern and on restrictions for certain groups of PFAS, reflecting the broader objectives established under the original strategy.

Where Policy Has Changed

Although the CSS remains an important policy framework, Europe's broader regulatory environment has shifted since 2020.

Industry analyses, including Deloitte's 2026 Chemical Industry Outlook, describe a growing emphasis on competitiveness and simplification. According to Deloitte, policymakers have scaled back elements of the wider sustainability agenda through omnibus legislative packages designed to reduce administrative burdens while maintaining core environmental protections.

This does not mean sustainability objectives have disappeared. Instead, implementation has become more selective, with greater attention given to balancing environmental goals against economic competitiveness and investment.

What Procurement Teams Should Monitor

For chemical buyers, regulatory planning should focus on measures that are already active rather than proposals that remain under discussion.

Priority areas include:

• Monitoring updates to the SVHC Candidate List and assessing whether purchased substances may become subject to additional obligations.

• Confirming supplier compliance with applicable PFAS restrictions where relevant.

• Understanding how the OSOA framework may influence future chemical assessments and regulatory consistency.

• Reviewing supplier documentation regularly to ensure it reflects the latest EU requirements.

Companies that monitor these developments proactively will be better positioned to manage regulatory change without disrupting supply chains.

Supplier Verification Becomes More Important

As regulatory requirements evolve, procurement professionals should place greater emphasis on supplier verification rather than relying solely on historical approvals.

Best practices include:

• Requesting updated regulatory declarations during supplier qualification.

• Confirming compliance with current EU legislation rather than previous regulatory frameworks.

• Monitoring changes affecting raw materials used in formulations.

• Maintaining records that demonstrate supplier due diligence.

• Working with suppliers that actively communicate regulatory developments.

These practices improve supply chain resilience while reducing the likelihood of unexpected compliance issues.

The Bottom Line for EU Chemical Buyers

The Chemicals Strategy for Sustainability remains a major influence on European chemical regulation, even though its implementation has evolved since its introduction in 2020. Some flagship initiatives, including One Substance, One Assessment, are now operational, while work continues on areas such as safe and sustainable-by-design chemicals, PFAS management and substances of very high concern. At the same time, broader EU policy has placed greater emphasis on simplifying regulatory requirements and strengthening industrial competitiveness through omnibus legislative changes.

For procurement professionals, the most effective approach is to focus on implemented requirements rather than anticipated reforms. Regular supplier verification, ongoing monitoring of EU regulatory developments and thorough documentation remain the foundation of successful compliance planning throughout the second half of 2026.

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