Policy briefs

Policy briefs

Published on 04 Aug 2026

What does it take to get REACH to where it needs to be? What was ChemSec’s reply to the PFAS public consultation? What did we write to top EU leaders in a joint letter with 35 other environmental NGOs?

Find out all of this — and much more — right here on this page. This is where you find ChemSec policy briefs, open letters and official input to EU policy processes.

2026

On the proposed chromium (VI) restriction

AUGUST 2026 — ChemSec welcomes the opportunity to provide feedback on the draft SEAC opinion regarding the restriction proposal for chromium (VI) substances.

Feedback on CARACAL 58

JULY 2026 — ChemSec offers feedback on the latest CARACAL meeting, including notes on the REACH Restrictions Roadmap, Innovation and Substitution Hubs, and Critical Chemicals Alliance.

Criticality within planetary boundaries

JUNE 2026 — 20 organisations, including ChemSec, author a joint position statement on criticality within planetary boundaries and a public interest approach to critical chemicals for Europe’s industrial transition.

On improving REACH regulation

JUNE 2026 — The European Environmental Bureau, ChemSec, and other NGOs sign a join position statement with recommendations on improving the implementation, enforcement and modernisation of REACH.

On the CMR restriction in childcare articles

JUNE 2026 — ChemSec welcomes and supports in general the proposed restriction of CMR substances in childcare articles. We urge the REACH Committee to conclude swiftly and the Commission to adopt the restriction as soon as possible.

Hazard and risk in EU chemicals legislation

JUNE 2026 — Hazard and risk are two central concepts in EU chemicals legislation. However, to provide strong protection against the most harmful substances, it is important to give hazard centre stage. This is best done with the generic risk approach (GRA).

Improving REACH in line with CSS

MARCH 2026 — ChemSec, the European Environmental Bureau (EEB) and ClientEarth share our list of priorities for advancing Chemical Strategy for Sustainability (CSS) commitments through comitology and better implementation.

EU leaders must deliver safer chemicals

FEBRUARY 2026 — Europe is facing a chemical pollution crisis, contributing to severe diseases and resulting in billions of Euros in health, environmental, and societal costs each year. 36 NGOs sent a letter to top EU leaders demanding they stay true to REACH’s primary objective: a high level of protection of human health and the environment.

Debunking ‘PFAS competitiveness’

FEBRUARY 2026 — When “competitiveness” is used to defend forever chemicals, it’s worth asking what’s being left out of the conversation. A new EU-commissioned report takes aim at the PFAS restriction proposal — but does their argument hold up? (Spoiler: it doesn’t)

2025

On proposed EU substitution centres

OCTOBER 2025 — As participants at the workshop held September 18, 2025, ChemSec was given the opportunity to provide written comments on the proposed network of EU substitution centres.

On the recent PFAS restriction proposal

SEPTEMBER 2025 — The European Chemicals Agency recently published an update to the EU-wide PFAS restriction proposal, which included some pretty eye-catching changes. Unfortunately, not for the better. Here are 5 key takeaways from the 3,500+ page document.

On the proposed Chemicals Action Plan

JULY 2025 — The recently released Chemicals Action Plan seems to raise more questions than answers and does very little to inspire confidence in the future of safer chemical use. Here’s what we have to say on the matter.

Feedback on CARACAL 54

APRIL 2025 — ChemSec responds to the European Commission’s suggestions for revising REACH at CARACAL 54.

Letter: Ambitious REACH revision key for Circular Economy

APRIL 2025 — Companies across sectors have written to Ursula von der Leyen, asking the EU Commission to deliver an ambitious revision of REACH that prevents harm from chemicals and avoids “circular pollution”. Read more.

What to look out for in the REACH revision

MARCH 2025 — Next week, Member State policy experts will gather in Brussels to hear the EU Commission’s ideas for simplifying REACH. Here is what they should look out for.

On chemicals in a future-proof economy

MARCH 2025 — Europe has turned to industrial policy to future-proof its economy and combat climate change. But without simultaneously tackling the chemical pollution crisis, the EU’s industrial policy plan could cripple the very economy it’s trying to strengthen. Here’s how to protect people and planet and boost industry at the same time.

What the REACH revision should look like

JANUARY 2025 — It is no secret that Europe’s chemicals regulation needs a facelift. ChemSec is determined to help overworked officials with their most challenging task — to simplify REACH and protect people and the planet in the same go.

2024

How to clarify PFAS in REACH

DECEMBER 2024 — The EU Commission president, Ursula von der Leyen, has said she aims to simplify the REACH regulations and provide clarity on or PFAS. ChemSec has sent her two letters to sharpen her thinking. Here is the second.

How to simplify PFAS in REACH

DECEMBER 2024 — The EU Commission president, Ursula von der Leyen, has said she aims to simplify the REACH regulations and provide clarity on or PFAS. ChemSec has sent her two letters to sharpen her thinking. Here is the first.

5 industry myths about the PFAS ban

NOVEMBER 2024 — Shout so loud that nobody can think clearly. This seems to be industry’s tactic for stopping the EU’s PFAS ban. As manufacturers turn up the volume, we examine five key myths behind the propaganda.

On Essential Use in chemicals policy

MAY 2024 — Last week, the EU Commission sent out a communication on the concept of Essential Use. We gave three of our policy experts the task of reading the text inside and out, leaving no stone unturned. Here is what stood out for them.

2021

Removing chemical roadblocks from the Circular Economy

FEBRUARY 2021 — While there is a substantial buy-in to recycling from decision-makers and companies alike, a number of roadblocks still need to be addressed before the circular economy can fully gain momentum. Watch the webinar.

How to improve recycling of plastics in electronics

FEBRUARY 2021 — An overarching problem with the recycling of electronics is legacy chemicals. Here are five ideas on how to make recycling of plastics in electronics work better. Read more.

2020

The problems facing textiles in the Circular Economy

NOVEMBER 2020 — “Circular economy” has been a buzzword in the policy sector for a long time. Together with ambitious industry representatives who are struggling to find quality recycled materials without toxic chemicals, ChemSec explored the topic as it relates to textiles. Read more.

Circular Economy action plan must contribute to toxic-free environment

JANUARY 2020 — ChemSec and CHEM Trust welcome the consultation on the roadmap towards a new circular economy action plan by the Commission but are concerned by the missing consideration of the toxic-free environment objective set by the European Green Deal.

2019

The Missing Piece – Chemicals in Circular Economy

MARCH 2019 — As the world seems intent on solving the problems of pollution and depletion of the earth’s resources by increas­ing recycling, little attention is paid to the contents of the old products that we turn into new ones. What role do chemicals play in the circular economy? And how will the circular economy work if no one wants to use recycled materials? Read more.

2018

A Circular Economy free from hazardous substances

JULY 2018 — The following companies and organisations represent a sample of stakeholders committed to circular economy. We urge the Commission to take their statements into consideration and to respect their needs. Read more.

Circular Economy must address hazardous chemicals in recycled materials

MARCH 2018 — Our interest in recycling – turning old products into new ones – is growing by the day. But how much of the material is actually usable, not just from an economic standpoint but also from the perspective of health and the environment? Read more.

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