prodchem
Aug 27, 2026
Five years after the European Commission launched its Chemicals Strategy for Sustainability (CSS) in October 2020, the EU has moved from broad policy ambition toward a more integrated chemicals-regulation framework. The strategy was designed to protect human health and the environment, phase out the most harmful substances where alternatives are available, encourage safer chemicals and strengthen Europe's industrial resilience.
At its midpoint, however, the picture is mixed. The EU has delivered important structural reforms, particularly through the new “one substance, one assessment” framework, while major objectives such as the comprehensive PFAS restriction and the full revision of REACH remain works in progress. The result is a strategy that has made meaningful progress but has not yet delivered the toxic-free environment originally envisioned.
The CSS was introduced as a central part of the European Green Deal's zero-pollution ambition. Its objectives extend beyond controlling individual chemicals. The strategy seeks to change how chemicals are designed, produced, used and regulated throughout their life cycles.
Its main priorities include:
Phasing out the most harmful chemicals from consumer products where their use is not essential.
Reducing exposure to endocrine disruptors and persistent toxic substances.
Phasing out PFAS unless their use is demonstrated to be essential.
Promoting safe and sustainable by design (SSbD) chemicals and materials.
Improving Europe's resilience and security of supply for critical chemicals.
Creating a more coordinated system for chemical safety assessments.
This makes the CSS considerably broader than a conventional regulatory program. It is simultaneously a health policy, environmental strategy and industrial-transformation agenda.
One of the clearest achievements has been the development of the “one substance, one assessment” (OSOA) approach.
Three pieces of legislation adopted in 2025 entered into force on 1 January 2026, reallocating technical responsibilities between EU agencies, establishing a common data platform on chemicals and creating a monitoring and outlook framework.
The objective is straightforward: the same chemical should not have to undergo disconnected safety assessments under different pieces of EU legislation when the underlying scientific questions overlap.
A more coordinated system should improve consistency, reduce duplication and allow regulators to identify risks earlier. The new common data platform is expected to become an important foundation for this system over the coming years.
Grade: B+
The architecture is a significant improvement, but its ultimate success will depend on how quickly the new system translates into faster regulatory decisions and better data sharing.
PFAS remains one of the most important tests of whether the CSS can deliver on its toxic-free ambition.
The EU has already adopted restrictions on specific PFAS groups. In September 2024, the Commission adopted restrictions covering PFHxA and related substances, including uses in consumer textiles, food packaging, consumer mixtures, cosmetics and certain firefighting-foam applications.
At the same time, the EU is pursuing a much broader approach. National authorities submitted a proposal to ECHA in 2023 seeking a restriction covering PFAS as a group rather than continuing exclusively with substance-by-substance regulation. The Commission has stated that it will develop its proposal based on ECHA's scientific opinion.
The delay is understandable given the technical and economic complexity of regulating thousands of substances simultaneously. But PFAS contamination continues to create environmental and economic costs, making the pace of action an important weakness.
Grade: B-
The direction is clear, but the flagship PFAS objective remains unfinished.
The CSS aims not simply to restrict hazardous chemicals but to encourage the development of better alternatives.
In March 2026, the Commission adopted a revised recommendation on the Safe and Sustainable by Design assessment framework. The updated approach strengthens the connection between chemical innovation, sustainability and European industrial competitiveness.
This is strategically important because substitution cannot depend entirely on regulation. If Europe restricts hazardous substances without creating economically viable alternatives, manufacturers may face higher costs, supply shortages or increased dependence on imports.
The SSbD framework attempts to shift investment toward chemicals and materials that are safer throughout their life cycles.
Grade: B
The policy framework is developing well, but its real test will be whether SSbD becomes a routine commercial criterion for product development and investment rather than remaining primarily a voluntary assessment concept.
The CSS also seeks to address a long-standing problem in chemical regulation: fragmented information.
The new common data platform and monitoring framework are intended to make chemical information more accessible and improve the ability of regulators to identify emerging risks. The Commission expects the platform to support more consistent assessment across different regulatory areas.
This could have major implications for chemical manufacturers and downstream users.
Better data visibility can make it easier to determine:
Which substances are present in products.
Where exposure occurs.
Which chemicals require substitution.
Where regulatory risks are emerging.
Which alternatives are available.
However, companies will also face greater expectations around data quality, supply-chain transparency and regulatory documentation.
Grade: B
The EU is building the infrastructure needed for better chemical intelligence, but the system is still transitioning from policy design to operational implementation.
The largest criticism of the CSS is not necessarily its ambition but its pace.
The strategy contains more than 80 actions, and the Commission maintains an implementation tracker to monitor progress. Several foundational initiatives have now moved forward, but major legislative reforms have taken years to develop.
For industry, slow regulation can create uncertainty. Companies may hesitate to invest in alternative chemistry when they do not know precisely when a restriction will take effect. At the same time, environmental groups may argue that prolonged regulatory processes delay necessary risk reduction.
The EU therefore faces a difficult balance: regulations must be scientifically robust and economically workable, but they also need to move quickly enough to address persistent chemical risks.
Grade: C+
The strategy has produced important reforms, but the implementation timeline remains its weakest dimension.
The midpoint evaluation also needs to consider Europe's chemical industry.
Chemical regulation can impose substantial costs through reformulation, testing, registration, reporting and substitution. Yet the CSS increasingly treats safer chemistry as an industrial opportunity rather than simply a compliance cost.
The Commission's current approach links chemical safety with clean industrial competitiveness, resilient supply chains and innovation. It has also emphasized the strategic importance of critical chemicals and sustainable sourcing.
This creates an important market shift.
Chemical companies that invest early in alternative formulations, safer materials and transparent supply chains may be better positioned for future regulation. Companies heavily dependent on substances likely to face restrictions could instead experience stranded assets or costly substitution programs.
For chemical-market participants, the CSS is gradually changing the definition of regulatory risk.
Previously, companies could focus primarily on whether a substance was currently restricted. The CSS encourages a more forward-looking approach.
Suppliers increasingly need to ask:
Is this substance likely to become restricted?
Is there a safer alternative?
Can the product demonstrate safe and sustainable-by-design characteristics?
Can the supply chain provide sufficient regulatory data?
Is the chemical strategically important to European manufacturing?
This makes regulatory intelligence an increasingly important component of chemical procurement and portfolio management.
The EU's PFAS approach illustrates the broader direction of the CSS.
Rather than waiting for evidence of harm from each individual substance, regulators are increasingly considering groups of chemicals that share persistence, mobility or other concerning characteristics.
For chemical companies, this means historical regulatory strategies based entirely on individual substance assessments may become less effective.
Portfolio-level screening is becoming more important.
A company with dozens of fluorinated products, for example, may need to evaluate the regulatory trajectory of the entire product family rather than waiting for each individual substance to appear on a restriction list.
CSS Objective | Midpoint Assessment | Grade |
|---|---|---|
One substance, one assessment | Major structural progress | B+ |
PFAS phase-out | Important restrictions, broader action pending | B- |
Safe and Sustainable by Design | Framework strengthened in 2026 | B |
Chemical data and monitoring | New EU-wide infrastructure developing | B |
Regulatory speed | Progress remains slower than ambition | C+ |
Industrial resilience | Increasingly integrated into chemicals policy | B |
Overall implementation | Strong foundations, major work remains | B |
The next phase of the CSS will determine whether the EU can convert its regulatory architecture into measurable reductions in chemical exposure.
Three areas will be particularly important.
First, REACH reform. A more efficient REACH system could accelerate restrictions while reducing unnecessary administrative complexity.
Second, PFAS. The eventual EU-wide PFAS restriction will be one of the most consequential chemical-policy decisions of the decade.
Third, implementation. The new OSOA framework, common data platform and SSbD approach must move beyond institutional reform and become practical tools used by regulators and industry.
The EU is also strengthening monitoring of PFAS in drinking water and pursuing broader environmental controls, demonstrating that chemical policy is increasingly connected across water, products, industrial emissions and waste management.
At its midpoint, the Chemicals Strategy for Sustainability deserves a B.
It has succeeded in establishing a clearer long-term direction and has delivered important regulatory infrastructure. The January 2026 implementation of the “one substance, one assessment” framework and the strengthening of safe-and-sustainable-by-design principles are meaningful achievements.
But the strategy has not yet fully delivered on its most ambitious objectives. PFAS regulation remains incomplete, REACH reform continues to evolve, and the pace of implementation has sometimes lagged behind the urgency of the environmental challenge.
The next five years will therefore be decisive.
The EU has built much of the regulatory machinery for a toxic-free environment. The real test now is whether it can use that machinery quickly enough to transform the chemicals market itself.
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