Germany Opposes REACH Revision – What Does the “Chemieagenda 2045” Indicate?
In response to the deepening crisis in Germany’s chemical industry, the German government presented a strategic document at the end of March, provisionally titled “Chemieagenda 2045.”
The overall message of the document is clear: competitiveness of enterprises must be strengthened through both short-term support measures and long-term transformation of the sector. Among the measures outlined are subsidised energy prices for industry, the expansion of compensation mechanisms, and actions aimed at ensuring stable supply chains.
An equally important factor for the competitiveness of the chemical industry is the issue of deregulation—or rather, the avoidance of further regulatory burden. In today’s challenging conditions for the entire European industry, the prospect of further tightening or complicating legislation is becoming increasingly difficult, if not impossible, to accept. The European Commission appears to recognise this issue, as evidenced by the postponement of the implementation of changes to the CLP Regulation (the “stop-the-clock” mechanism). A similar approach is now reflected in the position of the German government, which clearly indicates its opposition to further tightening of the legislative framework for chemical products.
No to Tightening and Deep Revision of REACH
For some time, stakeholders have been expecting changes to the REACH Regulation and awaiting the publication of a revised proposal. It was anticipated that a draft would be released before the end of 2025; however, this has not occurred. One possible reason is the instability of global markets and the declining competitiveness of EU industry, which forces policymakers to carefully reassess the economic impact of any proposed changes.
Against this backdrop, the position of the German government—reflected in the “Chemieagenda 2045”—is particularly significant. It can be summarised as follows:
- There is currently no support for a comprehensive revision of the core legal act governing the chemical industry, namely the REACH Regulation;
- Attempts to introduce selective amendments to the annexes of REACH are also viewed negatively;
- In the current geopolitical context, regulatory changes—especially those aimed at tightening requirements—would have adverse effects on the competitiveness and innovation capacity of the EU chemical industry.
Germany is calling on the European Commission to review the existing legislative framework and to simplify it in a targeted and practical manner, while maintaining a high level of protection for human health and the environment. Importantly, this is not about “deregulation” in the sense of making it easier to place chemical products on the market, but rather about simplifying and accelerating the legal mechanisms associated with these processes.
What Does This Mean for the REACH Revision?
It is difficult to predict how the European Commission will respond to the German government’s position. However, it should be noted that Germany remains the largest economy in the European Union, with a strong—despite current challenges—chemical sector. As such, its stance is highly influential in shaping EU chemicals policy.
The lack of support from the German government for a deep revision of REACH may result in delays to the revision process and a more limited scope of changes than initially expected. It also appears that the European Commission shares, at least to some extent, Germany’s perspective on the need for simplification and enhanced competitiveness of EU industry.
As a result, in the short term, companies should not expect any major “earthquake” in REACH legislation.
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