COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS A European Chemicals Industry Action Plan
Date: 2025-07-08
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EU action, EU production, chemical industry, circular economy, competitiveness, energy supply, innovation, international trade, reduction of gas emissions, regulatory policy

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 8.7.2025  COM(2025) 530 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS A European Chemicals Industry Action Plan  
 
 
COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

A European Chemicals Industry Action Plan 

1. 

INTRODUCTION 

The  chemical  industry  is  the  industry  of  the  industries.  As  the  EU’s  fourth  largest 
manufacturing  industry,  it contributes  to  over 96% of manufactured goods, making it a 
cornerstone of the EU’s industrial resilience and competitiveness. Chemicals are crucial 
for a wide range of applications in strategic sectors such as defence, cleantech and digital. 
Europe therefore needs to keep a strong chemicals industry. At the same time, the industry 
needs  to  transition  to  a  clean  and  circular  economy  model,  embracing  innovation, 
strengthening its global competitiveness and ensuring the protection of human health and 
environment.  

Yet today, the sector also faces significant challenges that threaten its competitive position 
and resilience. Its global market share has declined by over 50% since 2003, with other 
regions,  such  as  China,  emerging  as  major  players.  High  energy  and  feedstock  prices, 
geopolitical  tensions,  and  low  market  demand  have  eroded  the  competitiveness  of  EU-
based  producers,  leading  to  declining  production  utilisation  rates.  The  past  two  years 
witnessed the announcement of closures of more than 20 major production sites1 in the 
EU, including steam crackers and other upstream facilities used for producing fundamental 
building blocks.  

This Action Plan builds on the Competitiveness Compass2, the Clean Industrial Deal3 and 
the Strategic Dialogue with the Chemical Industry, held by President von der Leyen on 12 
May 2025. It sets out concrete measures to help secure the global competitiveness of the 
European  chemicals  industry,  to  maintain  a  strong  European  production  base  and  to 
upgrade it through action in four key areas: 1) strengthening resilience: maintaining critical 
production in EU and opening new markets and protecting the EU industry  2) securing 
energy supply, supporting decarbonisation and shift towards clean and circular economy; 
3)  creating  lead  markets  and  promoting  innovation;  and  4)  simplifying  the  regulatory 
framework.  

The  Action  Plan  is  accompanied  by  an  Omnibus  legislative  proposal  on  chemicals4,  to 
simplify, for example, labelling requirements,  as  well as  a  delegated act  on low-carbon 

(1)  It is estimated that these major sites account for 10 000 - 20 000 job losses.  
(2)  Communication from the Commission to the European Parliament, the Council, the European Economic 
and  Social  Committee and the  Committee of the  Regions  - A Competitiveness Compass for the EU, 
COM(2025) 30 final. 

(3)  Communication from the Commission to the European Parliament, the Council, the European Economic 
and Social Committee and the Committee of the Regions - The Clean Industrial Deal: A joint roadmap 
for competitiveness and decarbonisation, COM(2025) 85 final. 

(4)  Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) 
No  1272/2008,  (EC)  No  1223/2009  and  (EU)  2019/1009  as  regards  simplification  of  certain 
requirements and procedures for chemical products, COM(2025) 531 

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hydrogen5. It is complemented by a proposal for the European Chemicals Agency (ECHA) 
Basic  Regulation 6,  further  simplifying  the  governance  of  the  regulatory  framework  of 
chemicals.  

2.  STRENGTHENING RESILIENCE  

2.1.  Maintaining critical production in the EU 

The EU must maintain and upgrade its core chemical production capacity, to strengthen its 
competitiveness  and  preserve  its  resilience.  The  primary  building  blocks,  such  as 
petrochemicals, ammonia and chlorine are the foundation of numerous value chains, from 
pharmaceuticals to batteries. Yet, the EU has lost at least 8-10% of its cracking capacity 
over the last three years, with potential future closures bringing the total loss to more than 
20% of the 2021 capacity. Most remaining EU crackers, concentrated in a few regions and 
often  integrated  with  oil  refineries,  are  outdated,  rely  heavily  on  naphtha  as  a  primary 
feedstock, and are less efficient than their global competitors7.  

These structural weaknesses are not limited to steam crackers. Other critical productions8 
have  faced  widespread  shutdowns,  creating  ripple  effects  on  the  whole  chemical 
ecosystem.  This  not  only  affects  sectors  such  as  plastics,  polymers,  and  consumer  and 
specialty chemicals, it also puts up to 200 000 direct jobs at risk.9 

To preserve and modernise strategic production capacities and value chains, decarbonise 
the sector, reduce dependencies10 and attract the right skills, the Commission will establish 
a Critical Chemicals Alliance11. This Alliance will act  as a strategic umbrella that enables 
cooperation with Member States and stakeholders, so that the risks of production capacity 
closures  in  the  sector  can  be  mapped  and  addressed.  The  Alliance  will  also  facilitate 
discussions on key trade challenges, such as global level playing distortions, supply chain 
dependencies,  and  intellectual  property  rights  issues,  by  helping  the  industry  and  the 
Commission to detect potentially harmful import surges at an early stage. This work will 
draw on the Transition Pathway for the Chemical Industry. 

The Alliance will help develop criteria for identifying chemical sites and molecules that 
are  critical  for  the  EU’s  strategic  objectives.  These  should  reflect  their  importance  for 
downstream strategic sectors, as well the level of EU trade dependencies. Building on the 
experience of the other strategic industries, such as raw materials or net-zero, it could also 
explore  new  resilience  factors  relevant  to  the  chemicals  sector,  such  as  rare  or  limited 
replication production sites critical to the value chains in the Union.  

Based on these criteria, the Alliance will contribute to mapping critical molecules, such 
as those that are essential for strategic value chains and subject to dependency on a single 

(5)  COMMISSION DELEGATED REGULATION (EU) …/... supplementing Directive (EU) 2024/1788 
of the European Parliament and of the Council by specifying a methodology for assessing greenhouse 
gas emissions savings from low- carbon fuels, C 2025 (4674) 

(6)  Proposal for a Regulation of the European Parliament and of the Council on the European Chemicals 
Agency  and  amending  Regulations  (EC)  No  1907/2006,  (EU)  No  528/2012, (EU)  No 649/2012  and 
(EU) 2019/1021, COM 2025 (386) 

(7)  In particular, ethane crackers common in the US and Middle East. 
(8)   The include amongst the others olefins, aromatics, methanol, ammonia and chlorine.  
(9)   CEFIC report: “the Competitiveness of the EU Chemical Industry”. 
(10)   For instance, on fertilisers 
(11)  in compliance with the competition rules and EU’s international commitments. 

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third  country  or  a  few  suppliers12.  Such  molecules  would  subsequently  benefit  from 
enhanced monitoring under the Customs Surveillance System and could serve as a basis 
for a potential legislative proposal.  

The Alliance will also support the EU and Member States in aligning investment priorities 
and  guide  coordination  of  EU  support  mechanisms  with  national  projects,  including 
Important Projects of Common European Interest (IPCEIs). Two potential IPCEIs could 
benefit the chemicals sector. First, the Joint European Forum for IPCEI (JEF-IPCEI) is 
looking at the biotechnology value chain to identify possible projects. Second, the Forum 
endorsed  a  project    on  circular  advanced  materials  and  its  design  is  currently  ongoing. 
Member States may design aid measures to support IPCEIs for technologies crucial for the 
clean transition  or important  infrastructure projects.  Whether or not  an IPCEI emerges 
will depend on the fiscal capacity of the participating Member States. 

Third, the Commission will assist Member States and regions in designating EU Critical 
Chemical Sites. They would build on already existing industrial clusters  and platforms 
such as the European Chemical Regions network. Such local industrial ecosystems have a 
crucial role to play in maintaining resilient value chains in sectors like clean technologies, 
aerospace, defence or health - sectors that require an agile and modernised production base.  

Many of these sites require investments to modernise, depollute and decarbonise, while 
increasing competitiveness.  Targeted support should be made available to modernise sites 
at risk of closure and to facilitate their green transition, in line with State aid rules where 
applicable.  

There are around 150 chemical parks across the EU. They anchor industrial activity, jobs, 
and centres of excellence and innovation. The Commission will help safeguard and support 
the development of these ecosystems through,  modernisation and decarbonisation, using 
cohesion funding, both under the current legal framework and following from the proposed 
communication on a modernised cohesion policy13. It will build on the experience of Just 
Transition  Fund  on  decarbonisation,  upskilling/reskilling  and  capacity  building,  the 
Innovation  Fund  and  InvestEU.  Currently,  the  Commission  already  supports  the 
decarbonisation  of  the  chemical  industry  with  the  Just  Transition  Fund  and  the  just 
transition process. 

Investments  could  be  supported  through  the  co-creation  of  regional  plans  for  the  EU 
Critical  Chemical  Sites,  bringing  together  industry,  academia,  start-ups,  and  regional 
authorities.  This  should  result  in  better  matching  local  needs  with  available  resources, 
infrastructures and instruments, and would allow innovative companies and start-ups to 
bring  new  solutions 
in  modernising  critical  production  processes,  accelerating 
decarbonisation,  digitalisation,  and  circularity  as  well  as  promoting  safer  and  more 
sustainable  chemicals.  This  collaborative  groundwork  can  help  improve  matchmaking 
with EU funding instruments. In this regard, the Commission could inform Member States 
of relevant funding opportunities and reduce the risk that promising projects fall through 
the cracks due to administrative complexity or fragmented support. 

(12)  For  critical  raw  materials  is  addressed  in  the  Raw  Materials  Information  Systems  RMIS  

https://rmis.jrc.ec.europa.eu/ 

(13)  Commission Communication “A modernised Cohesion policy: The mid-term review”, COM(2025) 163 

final, 1 April 2025 

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This initiative will also help with providing administrative assistance to  other measures 
such as strengthening research-industry collaboration, promoting innovation, supporting 
SMEs and upskilling/reskilling of local workforce14. 

The  implementation  of  the  current  Action  Plan  will  also  rely  on  the  Competitiveness 
Coordination Tool, as presented in the Competitiveness Compass, to alleviate the sector’s 
dependencies on external factors and support its transition toward a more sustainable and 
competitive future.  

The Commission will: 

•  Establish a Critical Chemicals Alliance at EU level as a strategic umbrella structure for 
cooperation with Member States and stakeholders to address the risks of production 
capacity closures in the sector and discuss key trade challenges (Q4 2025). 

The Alliance will:  

•  Set  up  support  for  Member  States  and  stakeholders  to  develop  criteria  to  identify 

critical production sites and molecules in the EU (Q4 2025).  

•  Assist Member States and stakeholders in mapping critical molecules, which will serve 
as a basis for enhanced  monitoring  under the Customs Surveillance System, supply 
diversification, as well as a possible legislative proposal on critical molecules (2026).  
•  Assist  Member  States  and  Regions  in  setting  up  EU  Critical  Chemicals  Sites,  to 
facilitate  investments,  innovation,  improve  access  to  funding  and  assist  the 
modernisation of critical production capacities (2026). 

2.2. 

International  trade:  opening  new  markets  and  protecting  the  EU 
industry  

The European chemical industry is a leading exporter and a key contributor to Europe’s 
trade  balance.  In  2023,  the  value  of  chemical  exports  from  the  EU,  excluding 
pharmaceutical and medicinal products, reached EUR 285 billion, compared to EUR 241 
billion  in  imports.  Its  trade  surplus  is  mainly  attributed  to  the  downstream  segments 
(consumer  and  specialty  chemicals),  polymers  and  chemical  intermediates,  whereas  its 
trade deficit in the upstream segments reflects the EU’s dependence on imported energy 
and feedstock carriers (fossil energy and feedstocks, bio-based feedstocks) used to produce 
other chemicals. 

For the industry to regain its competitiveness within the EU and internationally, access to 
overseas markets for both exports and imports, along with a reinforced level playing field, 
is critical, for example in the area of intellectual property protection. To achieve this, the 
EU will take sector-specific actions as described below.  

Securing access to export markets  

The Commission will continue to expand the EU’s network of free trade agreements to 
reduce trade barriers and evaluate relevant aspects of existing trade agreements with a view 

(14)  Under the Pact for Skills a regional partnership led by the European Chemical Regions Network, has as 
primary commitment to assist regions in navigating the challenges posed by the industry's transition to 
green and digital practices. 

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to promoting trade in chemicals, including ensuring access to raw material inputs that are 
essential for the chemicals industry. 

The Commission will strive, in cooperation with stakeholders, to support the chemicals 
industry through other forms of agreements, where free trade agreements are currently not 
possible,  to  facilitate  market  access  and  promote  trade  through  alternative  tailor-made 
forms  of  engagement  with  our  partners.  These  might  include  sectoral  regulatory 
cooperation  agreements,  aiming  to  reduce  unnecessary  barriers  to  simplify  trade  in 
chemicals,  as well as Critical  Raw Materials  Strategic Partnerships or Clean Trade  and 
Investment  Partnerships  (CTIP),  in  order  to  secure  supply  chain  diversification  for 
essential critical raw materials inputs.  

Trade defence  

Where warranted, the Commission will continue to make fast and efficient use of trade 
defence  instruments,  such  as  anti-dumping,  anti-subsidy  or  safeguard  measures.  This 
should protect our industries from unfair global competition and ensure that our market 
does not serve as an export destination for trade diversion and state-induced excess global 
capacity.  

Between  1 January 2024  and  30 June 2025, the  Commission  initiated 18 trade defence 
investigations on imports of chemicals from third countries. In addition, on 30 June 2025 
there  were  46  measures  in  force  which  concern  chemicals.  The  majority  of  these  cases 
concern imports from China, likely due to a build-up of massive overcapacities.  While the 
EU industry was facing rising costs, Chinese producers steeply lowered their prices. This 
price  decrease  is  totally  disconnected  from  global  raw  materials  market  trends,  which 
points to dumping practices. 

The Commission will  strengthen the EU’s trade defence toolbox to respond more swiftly 
and effectively to unfair pricing practices in the chemical sector. It will also accelerate the 
fast  and efficient use of  trade defence instruments,  including  through close cooperation 
with  the  Chemical  Industry  Alliance  to  detect  such  practices.  The  Commission  will 
continue acting decisively against practices of evasion of anti-dumping measures, through 
application of anti-circumvention procedures. 

To ensure timely action based on accurate data, the Commission will continue to closely 
monitor imports of chemicals both under its newly created Import Surveillance Task Force 
and through the specific monitoring system introduced in March 2025 for certain industrial 
chemicals. This monitoring will be expanded to further molecules, notably to those under 
the list of critical molecules, once it is agreed. 

Customs and market surveillance  

Imports placed on the EU market must respect the same rules as EU-made products. This 
is a matter of credibility, industrial resilience, and consumer protection. The EU and its 
Member States will step up enforcement of EU chemicals legislation to close loopholes 
that  allow  non-compliant  imports,  particularly  through  online  platforms  or  unregulated 
intermediaries,  as  this  risks  distorting  competition  and  undermines  compliant  EU 
producers.  The  Digital  Product  Passport  will  play  a  role  in  supporting  this  goal,  by 
improving  transparency  along  value  chains  and  providing  reliable  and  comparable 
information on both EU and non-EU products.  

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This  requires  stepping  up  controls  at  the  border,  including  though  customs  reform  and 
better market surveillance. In addition, the EU should move towards targeted, risk-based 
checks  on  chemicals,  building  on  initiatives  like  those  outlined  in  the  e-commerce 
Communication15. This includes the development of harmonised enforcement priorities, 
such  as  checks  on  substances  in  articles,  restricted  chemicals,  or  mislabelled  mixtures. 
These efforts will help ensure that products entering the EU do not bypass safety rules, 
undercutting the internal market and weakening incentives to innovate. As outlined in the 
Single Market Strategy, the Commission is committed to take effective action to increase 
product  compliance  by  tapping  into  synergies  with  capacities  of  the  EU  and  national 
customs  and  market  surveillance  authorities  and  potentially  establishing  an  EU  Market 
Surveillance Authority16. 

To reinforce the compliance of imported goods with the relevant EU rules, the Commission 
will  strengthen  enforcement  through  improved  cooperation  and  information  exchange 
among  national  authorities,  ECHA,  and  customs  authorities.  This  will  involve  boosting 
coordination through Administrative Cooperation Groups (AdCos) and enhancing systems 
like the Information and Communication System on Market Surveillance (ICSMS) and the 
Safety  Gate  rapid  alert  system.  Additionally,  the  Commission  will  promote  better 
enforcement of existing rules, including under REACH, through the EU Single Window 
Environment for Customs and its future articulation in the context of the Customs Union 
Reform  and its  EU Customs  Data Hub as  well as  other custom systems. Also,  the next 
EMPACT (European Multidisciplinary Platform  Against Criminal  Threats) cycle 2026-
2029  presents  an  opportunity  to  strengthen  the  framework  against  counterfeit  goods, 
including chemicals. 17   

The Commission will: 

•  Continue collaborating with international partners to secure access to global markets, 
pursuing sectoral cooperation agreements where free trade agreements are not possible.  
•  Strengthen  the  monitoring  of  chemicals  under  the  Import  Surveillance  Task  Force 
including for trade defence responses to detect potentially injurious import surges early 
(Q3 2025). 

•  Support the development of harmonised risk-based controls for chemicals to reinforce 

the compliance of imported goods with the relevant EU rules. (Q4 2025). 

•  Coordinate  a  package  of  enforcement  and  market  surveillance  actions,  including 
through the integration of REACH through the EU Single Window Environment for 
Customs and its future articulation in the context of the Customs Union Reform and its 
EU Customs Data Hub, and other customs systems, as well as by prioritising chemicals 
in national market surveillance work plans (Q4 2025). 

3.  SECURING AFFORDABLE ENERGY SUPPLY AND SUPPORTING DECARBONISATION 

High energy prices are significantly undermining the cost-competitiveness of EU based 
chemicals  producers.  Energy  accounts  for  about  75%  of  production  costs  in  the  EU 
petrochemicals sector. Natural gas makes up over 70% of the variable costs of ammonia, 

(15)  A comprehensive EU toolbox for safe and sustainable e-commerce, COM(2025) 37 final.  

(16)  COM(2025) 500 final 

(17)  See also the Commission Communication “A comprehensive EU toolbox for safe and sustainable e-

commerce”, COM(2025) 37 final, 5 February 2025, p. 12.  

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while  electricity  accounts  for  over  60%  of  production  costs  in  industry.  Enhanced 
investment in interconnections and supply chains with Southern Neighbourhood partners 
under the New Mediterranean Pact will be a key asset. 

The chemical industry depends on imported fossil fuels not only as a source of energy, for 
example to generate heat in production processes, but also as raw material inputs for most 
chemical products. This dual dependency makes the sector uniquely vulnerable to fossil 
fuels price volatility and supply chain disruptions. While EU chemicals industry should 
gradually move away from these dependencies, it is essential that transition policies take 
account  of  the  sector’s  current  energy  and  feedstock  needs  to  ensure  resilience, 
decarbonisation and competitiveness. 

3.1. 

Securing affordable energy supply  

The Action Plan for Affordable Energy18 adopted in February 2025, aims to deliver lower 
prices to European energy consumers, including the chemical industry. The Commission 
will also continue to aggregate gas demand for EU companies to lower the overall energy 
costs.  

The  EU  Emission  Trading  System  (ETS)  indirect  cost  compensation  State  Aid 
Guidelines19  enable  Member  States  to  compensate  certain  energy-intensive  sectors 
(including  selected  chemical  sectors  or  products,  such  as  refined  petroleum  products, 
certain inorganic basic chemicals, some industrial gases or polyethylene) for the increase 
in  electricity  prices,  caused  by  the  application  of  the  EU  ETS.  The  current  State  aid 
framework does not  include  some chemical  sectors. However, as the price assumptions 
made  at  the  time  no  longer reflect  the  current  market  conditions,  with  prices  now  also 
affecting sectors like organic chemicals or fertilisers, the Commission will by the end of 
the year update the ETS State aid guidelines with the view to including, among others, 
additional chemical sectors. 

In  parallel,  the  Clean  Industrial  Deal  State  Aid  Framework  “CISAF”20,allows  Member 
States  to  grant  temporary  relief  on  electricity  costs  for  energy-intensive,  trade-exposed 
industries,  with  a  minimum  price  of  50  EUR/MWh,  on  condition  that  they  reinvest  in 
decarbonisation. The framework also allows for State aid support for deployment of a wide 
array of decarbonisation technologies such as electrification, hydrogen, biomass, carbon 
capture  utilisation  and  storage  as  well  as  de-risking  of  investments  in  clean  energy  or 
decarbonisation  projects.  Overall,  these  measures  will  help  deliver  decarbonisation 
investments  alleviate current energy cost pressures and support the continued production 
of chemicals in the EU.  

Faster permitting 

The  chemical  industry  often  requires  the  establishment  of  new  installations  or  the 
retrofitting and modernisation of existing infrastructure. This requires new permits. 

(18)  Communication from the Commission to the European Parliament, the Council, the European Economic 
and Social Committee and the Committee of the Regions - Action Plan for Affordable Energy Unlocking 
the true value of our Energy Union to secure affordable, efficient and clean energy for all Europeans, 
COM(2025)79 final. 

(19)  Communication from the Commission  Guidelines on certain State aid measures in the context of the 

system for greenhouse gas emission allowance trading post-2021, C(2020) 6400 final. 

(20)  Communication  From  The  Commission  -  Framework  for  State  Aid  measures  to  support  the  Clean 

Industrial Deal, (Clean Industrial Deal State Aid Framework), C(2025) 7600 

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The EU has already put in place legislation to accelerate and streamline the permit-granting 
process  for  some  industrial  installations,  through  the  Net  Zero  Industry  Act21  and  the 
revision  of  the  Industrial  Emissions  Directive22.  The  revised  Industrial  Emissions 
Directive23 sets up a new Innovation Centre on Industrial Transformation and Emissions 
(INCITE).  INCITE  will  identify  and  evaluate  innovative  techniques  to  showcase  their 
potential  and  promote  their  uptake  on  a  larger  scale.  The  most  effective  and  viable 
innovative techniques will be included in the conclusions on best available techniques.  

In  the  Defence  Readiness  package,  the  Commission  proposed  a  fast-track  permitting 
regime for defence readiness to enable a rapid scale-up of industrial capacity in response 
to  urgent  security  needs.  Building  on  the  experience  of  Net  Zero  Industry  Act,  the 
Commission  will  propose  later this year an  Industrial Decarbonisation Accelerator Act, 
with concrete measures to address permitting bottlenecks relating to the decarbonisation 
of energy intensive industries. Permitting challenges relating to environment assessments 
will be addressed in the environmental omnibus in Q4 2025.   

To accelerate the deployment of electrification projects, it is essential to accelerate grid 
access  for  chemical  installations,  ensuring  they  can  quickly  source  clean  energy  to 
transform  their production processes. As part of a European  Grid  Package, in  2025 the 
Commission will propose measures to accelerate access to grids, storage and renewables. 

Hydrogen 

Besides  its  use  for  electricity  generation,  hydrogen  is  necessary  for  a  cost-effective 
transformation of the EU chemical industry.  As a producer and consumer of hydrogen, 
the chemical sector is well positioned to support the development of hydrogen economies 
in the EU. Hydrogen will be key for the decarbonisation of various chemical products, for 
example through the production of low-carbon nitrogen fertilisers.   

The Commission will support the uptake of renewable and low-carbon hydrogen and the 
development of related infrastructure. The Commission has also launched a study to assess 
the effectiveness of the hydrogen framework to identify possible barriers to the upscaling 
of renewable hydrogen and assess the need for an adjustment of its regulatory framework.  

In  addition,  a  third  call  under  the  Hydrogen  Bank  will  be  soon  launched  to  support 
hydrogen production in Europe. On the same day as this Action Plan, the Commission also 
adopts  a  delegated  act  on  low-carbon  hydrogen  to  provide  certainty  to  investors  and 
promote the uptake of these technologies. The production and delivery of hydrogen is also 
one of the main objectives of the upcoming Trans-Mediterranean Energy and Clean Tech 
Cooperation Initiative. 

In addition to other forms of support, the free allocation rules in the EU ETS have been 
updated  to  ensure  technological  neutrality  in  the  carbon  leakage  protection  measures. 
Therefore, the production of hydrogen via electrolysis has been made eligible to receive 
free EU ETS emission allowances at the benchmark level set by traditional technologies. 

(21)  Regulation  (EU)  2024/1735  of  the  European  Parliament  and  of  the  Council  of  13  June  2024  on 
establishing a framework of measures for strengthening Europe’s net-zero technology manufacturing 
ecosystem, OJ L, 2024/1735, 28.6.2024. 

(22)  Directive 2010/75/EU of the European parliament and of the Council of 24 November 2010 on industrial 

and livestock rearing emissions (integrated pollution prevention and control). 

(23)  As amended by Directive (EU) 2024/1785 

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The Commission will: 

•  Update the State aid guidelines for ETS indirect cost compensation, with the view to 

including additional chemicals (Q4 2025). 

•  Propose  to  address  challenges  related  to  environmental  permitting  including  for 

decarbonisation projects under the environmental omnibus (Q4 2025).  

•  Propose  speeding  up  and  streamlining  other  aspects  of  permitting  (including 
digitalisation)  for  decarbonisation  projects  under  the  Industry  Decarbonisation 
Accelerator Act (Q4 2025).  

•  Propose facilitating grid access to energy intensive industries electrification projects 

(Q4 2025)  

3.2. 

Supporting decarbonisation and the shift to a circular economy  

Meeting net-zero ambitions and the shift to a circular economy model require investments. 
At the same time, the move towards safer and more sustainable chemicals offers significant 
opportunities to EU chemicals industry and downstream users. 

As one of sectors hardest to abate, the  chemical  industry requires a technology neutral, 
step-by-step  and  transitional  approach  to  decarbonisation.  Transitional  solutions  in 
particular, such as ethane crackers, will be important  in the process of transforming the 
sector.  

In  addition,  achieving  net  zero  and  reducing  strategic  dependencies  will  require  a 
progressive  shift  away  from  both  fossil  energy  and  virgin  fossil  feedstock,  where 
technically  and  economically  feasible.  Alternative  clean  carbon  sources  like  biomass, 
recycled waste and carbon from carbon capture utilisation (CCU) are essential for this.  To 
this end, the Commission will design incentives to build a viable business case for the clean 
transition of the EU chemical industry.  

EU financial support  

The EU budget supports innovation and decarbonisation projects throughout the different 
innovation stages. 

The Horizon Europe work programme 2026-2027 will support the transition to industrial 
decarbonisation at the earlier innovation stages with approximately EUR 370 million. In 
addition, as announced in the Clean Industrial Deal, the Commission will lauch a flagship 
Horizon Europe call of EUR 600 million under the 2026-2027 work programme to support 
fit  for-deployment  projects.  This  call  will  be  complementing  ongoing  research  and 
innovation efforts funded under Horizon Europe and will aim to foster synergies between 
the Framework Programme for research and investment (R&I) and the Innovation Fund, 
creating  a  pipeline  of  projects  from  R&I  to  deployment.  The  call  will  target  all  energy 
intensive industries, including the chemical industry. 

The Innovation Fund, set up by the EU ETS, provides incentives to invest in industrial 
decarbonisation. In the context of the ETS review in 2026, the Commission will take into 
account the specificities of the energy-intensive industries and it will propose to further 
enhance  this  toolbox  with  an  Industrial  Decarbonisation  Bank,  aiming  to  provide  up  to 
EUR  100  billion  of  funding  for  industrial  decarbonisation.  In  2025,  a  pilot  for  a  new 
Industrial  Decarbonisation  Bank  will  be  launched  with  a  EUR  1  billion auction  for  the 

9 

 
 
decarbonisation of key industrial processes, notably heat, which also in the chemical sector 
is one of the largest sources of energy demand and greenhouse gas emissions24.  

The  InvestEU  Fund  mobilises  public  and  private  investment  for  innovation  and  clean 
transition,  including  in  supporting  start-ups  and  scale-ups  in  clean  technologies.  An 
amendment to the InvestEU Regulation, currently under discussion by the co-legislators, 
proposed to increase the size of the InvestEU Fund and its offer to the market (notably 
guarantees, venture debt and equity financial products) by mobilising additional EUR 50 
billion of investment also to support the objectives of the Clean Industrial Deal’s objectives 
and initiatives implemented by the European Investment Bank Group, such as TechEU. 
The  revised  InvestEU  fund  will  be  able  to  provide  support  to  investments  benefiting 
energy-intensive  industries,  for  instance,  through  supporting  electricity  grid  equipment, 
clean tech guarantees and corporate Power Purchase Agreements for renewable energy. 

The future Competitiveness Fund will support decarbonisation efforts. Dedicated public 
private initiative could also be established to promote investments for the modernisation 
of  the  chemical  sector.  This  is  without  prejudice  to  the  next  Multiannual  Financial 
Framework proposal’s package. 

Bioeconomy and biomass  

Bio-based  feedstocks  can  offer  meaningful  alternatives  to  fossil  carbon  material25.  If 
designed  correctly,  using  locally  and  sustainably  sourced  bio-based  materials,  they  can 
reduce dependencies on global value chains (such as replacing fossil gas with biogas and 
biomass) and greenhouse gas emissions.  

Using  bio-based  alternatives  enables  the  production  of  safer  and  more  sustainable 
chemicals.  For example, microbial fermentation uses microorganisms to convert sugars 
and plant-based materials into valuable chemicals, reducing the need for petroleum-based 
processes. Enzymes in enzymatic processes are increasingly used in bio-based chemical 
production  as  catalysts  that  facilitate  more  sustainable  reactions.  These  processes  often 
require less energy and generate fewer harmful byproducts than traditional methods.  

Technological advances enable companies to convert waste materials and valorise waste, 
such as agricultural residues and food waste, into valuable biobased chemicals and bio-
fertilisers. This reduces the need for virgin raw materials and valorises waste. Moreover, 
there is a potential of exploiting current production capacity to use alternative feedstock 
and biobased materials.  At the same time, the protection of biodiversity and food security 
must be ensured.   

The upcoming Bioeconomy Strategy (Q4 2025) will aim to improve resource efficiency 
and  tap  the  significant  growth  potential  of  bio-based  materials  substituting  fossil-based 
materials, and related industries. This can also further reduce dependencies on imported 
raw  materials  for  the  EU  chemicals  industry.  The  strategy  will  define  a  vision  and 
directions  for  scaling  up  the  manufacturing  of  sustainable  bio-based  materials,  develop 
biotechnologies, promote innovation and investments in high-value applications, including 

(24)  cfde57b3-d80f-43e1-9ee4-cd96c42c6ca8_en  

(25)  Communication from the Commission to the European Parliament, the Council, the European Economic 
and Social Committee and the Committee of the Regions  - Building the future with nature: Boosting 
Biotechnology and Biomanufacturing in the EU, COM(2024)137 final. 

10 

 
 
for chemicals. Also, it will explore how to ensure chemical industry’s access to biomaterial 
for added value uses such as biochemicals. 

The  Commission  has  already  highlighted26  the  potential  of  sustainable  biomass  as  an 
alternative  feedstock27,  with  the  option  of  voluntary  labelling  of  bio-based  products  to 
create  lead  markets.  It  will  explore  further  options  to  incentivise  the  use  of  sustainable 
biomass as feedstock.   

Support for circularity  

Chemical recycling can play an important role in reducing the EU’s dependence on virgin, 
fossil-based  resources  for  plastic  production  and  valorise  end-of-life  products.  For 
example,  hard-to-recycle  waste  plastics  not  suitable  for  mechanical  recycling  or  where 
specific quality requirements need to be reached  can particularly benefit from chemical 
recycling. It would contribute to the EU’s targets for recycling plastic waste and increasing 
recycled content in plastics. 

To promote effective deployment of chemical recycling, the Commission is launching the 
public  consultation  on  an  implementing  act  under  the  Single-use  Plastics  Directive28  to 
establish a clear, science-based and technologically neutral framework on the mass balance 
allocation to account for recycling content from chemical recycling, allowing to create a 
lead  market  for  the  chemical  sector  to  become  more  circular.  An  implementing  act  is 
scheduled for adoption in Q4 2025.  

The proposal for a Circular Economy Act will address both the supply and demand side 
by  creating  a  single  market  for  waste  and  boosting  the  use  of  recycled  and  secondary 
materials. This presents a significant opportunity for the chemicals industry, which plays 
a central role in enabling circular solutions across value chains. 

Carbon Capture, Utilisation and Storage (CCUS) 

CCUS is a fundamental net-zero technology to reduce dependencies on fossil fuels and 
contribute to  the resilience of European industries, particularly  those harder to  electrify 
and to abate, such as chemicals, as outlined in the 2024  Industrial Carbon Management 
Communication29.  CCU  can  also  improve  industrial  symbiosis,  by  linking  sources  of 
industrial emissions to off-takers across local value chains.  

This requires a structured approach to planning infrastructure, covering both the demand 
and supply sides of captured CO2 and hydrogen networks. As a first step, the Delegated 
Act  under  the  Net  Zero  Industry  Act,  which  will  enter  into  force  shortly, outlines  the 
obligations  of  EU  gas  and  oil  producers  in  meeting  the  EU’s  2030  CO2  storage 
target. Furthermore, the Commission intends to draw up a dedicated legislative regime to 

(26)  Communication from the Commission to the European Parliament, the Council, the European Economic 
and Social Committee and the Committee of the Regions  - Building the future with nature: Boosting 
Biotechnology and Biomanufacturing in the EU, COM(2024)137 final. 

(27)  See  also the Vision for Agriculture and Food, adopted in February 2025, has set out perspectives to 
expand bioeconomy, to valorise by-products and waste, to accelerate market access for biopesticides 
and to support the uptake of low-carbon fertilisers from recycled nutrients and digestate from biogas. 
(28)  Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 2019 on the reduction 

of the impact of certain plastic products on the environment, OJ L 155, 12.6.2019, p. 1. 

(29)  Communication from the Commission to the European Parliament, the Council, the European Economic 
and  Social  Committee  and  the  Committee  of  the  Regions  -  Towards  an  ambitious  Industrial  Carbon 
Management for the EU, COM(2024)62 final. 

11 

 
 
ensure  the  progressive  development  of  an  EU  market  for  CO2  and  CO2  infrastructure, 
creating the trust and longer-term predictability for the value chain to take-off.  

The  successful  uptake  of  CCU  also  requires  a  supportive  regulatory  framework.  The 
current ETS rules do not recognise captured CO2 in non-permanent products, such as those 
produced by the chemical industry.  

As  part  of  the  2026  ETS  review,  the  Commission  will  assess  both  the  feasibility  of 
including  waste  management30  in  the  EU  ETS  and,  in  this  context,  how  to  best  reward 
captured CO2 in non-permanent products. In addition, it will assess the case of permanent 
carbon removals to compensate for residual emissions from hard to abate sectors.   

The Commission will:  

•  Adopt a new EU Bioeconomy Strategy to define a vision and directions for scaling up 
the manufacturing of sustainable biobased materials, develop biotechnologies, promote 
innovation  and  investments  in  high-value  applications,  including  for  chemicals  (Q4  
2025). 

•  Propose  a  Circular  Economy  Act  to  unlock  secondary  materials  markets  and  drive 

circularity in the chemicals (2026). 

•  Support the safe and effective deployment of chemical recycling under the Single-Use 
Plastic Directive: public consultation launched Q3 2025 and adopt an impmeneting act 
under the Single-use Plastics Directive concerning chemical recycling (Q4 2025).   
•  Assess  the  feasibility  to  accounting  emissions  from  non-permanent  CCU  products 

downstream as part of the ETS review (Q2/Q3 2026). 

•  Develop  financial  incentives  to  promote  the  uptake  of  non-fossil  carbon  as  well  as 

• 

renewable and low-carbon hydrogen. 
Improve the regulatory framework for carbon capture, transportation, utilisation and 
storage (CCUS), including by proposing a regulatory framework for developing an EU 
CO2 markets and infrastructure.  

4.  LEAD MARKETS AND INNOVATION  

4.1.  Lead markets and green taxation 

The  investments  in  non-fossil  feedstocks  and  low-carbon  technologies  are  often 
constrained by the lack of off-takers, rendering it difficult for frontrunner companies to 
reap the “green premium” and capitalise on investments. Therefore, within the logic of the 
upcoming reform of the public procurement, the Industrial  Decarbonisation  Accelerator 
Act will introduce EU content requirements, in line with the Union’s international legal 
commitments, as well as resilience and sustainability criteria with the objective to foster 
and safeguard clean European supply of energy-intensive products and European demand 
for downstream industries. 

Taxation can contribute to develop innovative, low-carbon solutions for the EU chemicals 
industry.  To  support  this  objective,  the  Commission  has  put  forward  the  Commission 
Recommendation on Tax Incentives to support the Clean Industrial Deal. This initiative 
provides  a  policy  signal  to  businesses,  encouraging  them  to  accelerate  their  transition 
towards clean tech, industrial decarbonisation and sustainable growth. It recommends the 

(30)  Waste  incineration  and  other  waste  management  processes,  such  as  in  particular  landfilling,  which 

creates methane and nitrous oxide emissions.  

12 

 
 
 
provision of tax credits for clean tech manufacturers as well as accelerated depreciation for 
heavy industries like the chemical sector when they invest in clean technology equipment. 

The Commission will: 

• 

Introduce EU content requirements as well as resilience and sustainability criteria to 
promote  lead  markets  for  specific  sectors  under  the  Industrial  Decarbonisation 
Accelerator Act (Q4 2025). 

4.2. 

Innovation  

Innovation is crucial for the chemical industry to remain competitive. It is fundamental to 
the  development  of  breakthrough  production  technologies,  for  example  those  based  on 
green chemistry, such as photochemistry, electrochemistry, and the development of new 
products  including  advanced  materials.  Innovation  also  benefits  downstream  users  and 
consumers by providing safer and more sustainable alternatives.  

The EU provides significant support to  early-stage innovation in the chemical industry, 
from the development of new concepts to pilot projects, under Horizon Europe, particularly 
within  European  partnerships,  such  as  Circular  Bio-Based  Europe  Joint  Undertaking31 
(CBE JU), Process4Planet32 and Innovative Advanced Materials for Europe (IAM4EU)33.  

However, scaling up innovative applications to industrial deployment remains a significant 
challenge. This is a sensitive stage in the innovation process, since it involves high levels 
of investments and considerable uncertainty, both in terms of technological performance 
and future market uptake.   

The  Commission  will  create  EU  Innovation  and  substitution  Hub(s)  to  overcome 
innovation barriers, accelerate the development of safer and more sustainable solutions and 
and will explore collaborative approaches to the substitution of targeted chemicals. These 
hubs, inspired by the INCITE model, will help companies, especially SMEs, in horizon 
scanning,  in  identifying  and  evaluating  alternatives,  fostering  partnerships,  and  sharing 
knowledge. The Safe and Sustainable by Design (SSbD) chemicals will be embedded in 
the Innovation Hubs, providing technical guidance from early-stage innovation. The SSbD 
framework  will  promote  collaboration  among  product  designers,  chemical  companies, 
scientists  and  research  organisations.  The  Commission  will  facilitate  access  to  the 
necessary  digital  and  physical  infrastructure  to  develop,  test  and  scale  up  SSbD 
innovations. 

These Hubs will also explore collaborative approaches towards the substitution of targeted 
chemicals  and  could  host  an  EU  Network  of  Substitution  Centres  to  provide  tailored 

(31) Circular Bio-based Europe Joint Undertaking (CBE JU) is a EUR 2 billion public-private partnership between 
the EU and the Bio-based Industries Consortium (BIC). It funds projects to advance competitive circular bio-
based  industries  in  the  EU  29  .  The  CBE  JU  is  financed  under  the  2021-2027  Multiannual  Financial 
Framework and operates under the rules of Horizon Europe for 2021-2031. 

(32)  The  Processes4Planet  (P4Planet)  Partnership’s  aim  is  to  transform  the  EU  process  industries  in  order  to 
achieve circularity and overall climate neutrality at the EU level by 2050 while also enhancing their global 
competitiveness. P4Planet is public-private partnership established between A.SPIRE (as the private entity) 
and  the  Commission  in  the  context    of  Cluster  4  (Digital,  Industry  and  Space)  of  Horizon  Europe. 
https://www.aspire2050.eu/p4planet/about-p4planet.  

(33) ‘Innovative Advanced Materials for Europe (IAM4EU), a Public-Private Partnership (PPP) under Horizon 
Europe for 2025-2027, with the aim to enhance the innovation of advanced materials, covering production, 
processes, and sustainability. 

13 

 
 
technical,  scientific  and  financial  support  to  companies,  especially  SMEs,  seeking  to 
replace hazardous substances with safer alternatives. 

The revised Commission recommendation on the framework for SSbD chemicals (2025) 
will  reinforce  EU  chemical  industry  competitiveness  by  making  the  innovation  process 
towards  safer  and  more  sustainable  alternatives  more  efficient. Horizon  Europe 
programmes 2025-2027 will provide about EUR 120 million to support the development, 
and acceleration of discovery, further enabled by AI and digitalisation, of alternatives to 
substances of concern. 

The Commission will roll out a Common Data Platform on Chemicals as part of the One 
Substance, One Assessment initiative, to simplify and make access to chemical data more 
transparent.  

The  upcoming  Advanced  Materials  Act  to  be  adopted  in  2026  will  also  stimulate  and 
reward  innovation  in  the  chemicals  sector.  Advanced  materials  deliver  the  innovative 
solutions for a more efficient, sustainable, and competitive industry. The Commission will 
put  forward  an  Advanced  Materials  Act  establishing  a  comprehensive  framework  to 
support the full value chain from research and development and startups to production and 
deployment and stimulate and reward innovation in the chemicals sector. 

Up to date chemical safety assessments 

Innovation plays also a crucial role in advancing chemical safety by improving chemical 
risk  management  and  supporting  the  development  of  safer  chemicals.  Strengthening 
collaboration across the chemical value chain is also essential to stimulate innovation in 
chemical risk assessment. The Partnership for the Assessment of Risks from Chemicals 
(PARC)  is  the  flagship  EU  initiative  in  this  area.  It  brings  together  ministries,  national 
public health and risk assessment agencies, research organisations and academia.  

New Approach Methodologies “NAMs” or animal-free testing approaches offer modern 
science-based tools to provide information for chemical risk assessment. They are key to 
accelerating risk assessments and closing information gaps and are cost-efficient tools. The 
Commission  will  continue working  to  modernise chemical  testing  and  to  accelerate the 
transition  to  animal-free  approaches.  As  part  of  the  One  Substance,  One  Assessment 
initiative, the Commission will launch a Common Data Platform on Chemicals to improve 
access to chemical data. In parallel, the Commission will present a roadmap to phase out 
animal  testing  for  chemical  safety  assessments  by  2026.  It  will  work  closely  with 
stakeholders  to  promote  alternative  methods,  to  avoid  unnecessary  testing  and  reduce 
testing  costs.  The  roadmap  will  outline  the  needs  for  test  method  development  and 
validation for animal-free methods, in line with the request made by the Council. 

The Commission will:  

•  Accelerate and scale up chemical innovation using voluntary EU Chemicals Innovation 

Hubs (Q1 2026). 

•  Propose an Advanced Materials Act to stimulate and reward innovation in the chemical 

sector (Q4 2026). 

•  Roll out a Common Data Platform for Chemicals as set out under the One Substance, 

One Assessment package. 

•  Present a roadmap for phasing out animal testing (Q1 2026). 

14 

 
 
5.  SIMPLIFYING AND STREAMLINING THE REGULATORY FRAMEWORK 

Simplification lies at the core of the Commission’s regulatory agenda, with a clear target 
to reduce the administrative burden for business by 25% and for SMEs by 35% until the 
end of this Commission’s mandate. 

5.1. 

“Simplification omnibuses”  

The Commission has adopted five “simplification omnibus packages” so far in 2025 to 
streamline rules and reduce  the administrative burden for  EU  industries. Some of these 
proposals, in particular those contained in the “first simplification omnibus” of 26 February 
2025,  are  directly  relevant  for  the  EU’s  chemical  industry34.  The  “fifth  simplification 
omnibus” of 17 June 2025 addresses aspects of defence and strengthens the possibility for 
Member States to exempt chemical substances, on their own, in a mixture or in an article, 
where this is necessary in the interests of defence. 

On  the  day  of  this  Action  Plan,  the  Commission  proposes,  as  a  first  step,  a  “sixth 
simplification omnibus” focusing specifically on the EU chemicals and related legislation: 
the  Classification  Labelling  and  Packaging  Regulation35  (CLP),  the  Fertilising  Product 
Regulation36  and  the  Cosmetics  Product  Regulation37.  The  proposal  simplifies  different 
rules in the chemical acquis while ensuring a high level of protection of human health and 
the environment. For instance, the proposal revises the provisions on mandatory font sizes 
and line spacing for the labelling of hazardous chemicals under the CLP, to make sure that 
chemical companies can effectively communicate information on substances and mixtures. 
This proposal will lead to estimated savings of at least EUR 363 million per year for the 
chemical industry. 

Beyond  today’s  simplification  omnibus,  the  Commission  will  further  simplify  EU 
legislation relevant to the EU chemicals industry. In Q4 2025, the Commission will adopt 
another  omnibus  proposal  aiming  to  reduce  administrative  burden  in  environmental 
legislation, which will be also relevant to the EU chemicals industry.  

Also,  the  Commission  will,  by  the  end  of  year,  put  forward  a  simplification  omnibus 
facilitating  biocontrol  in  farming.  Some  aspects,  such  as  facilitated  market  access  for 
biopesticides, will also be relevant to the chemical industry.  

Taxonomy 

As part of delivering the “first simplification omnibus”, the Commission will soon adopt 
revised  Do  No  Significant  Harm  (DNSH)  criteria  for  pollution  prevention  and  control 
under the Taxonomy for sustainable investments. Specifically, it will clarify and limit the 

(34)  Proposal  for  a  Directive  of  the  European  Parliament  and  of  the  Council  amending  Directives 
2006/43/EC,  2013/34/EU,  (EU)  2022/2464  and  (EU)  2024/1760  as  regards  certain  corporate 
sustainability reporting and due diligence requirements, COM(2025)81 final. 

(35)  Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on 

classification, labelling and packaging of substances and mixtures, OJ L 353, 31.12.2008, p. 1.  

(36)  Regulation (EU) 2019/1009 of the European Parliament and of the Council of 5 June 2019 laying down 
rules on the making available on the market of EU fertilising products, OJ L 170, 25.6.2019, p. 1. 
(37)  Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 

on cosmetic products (recast), OJ L 342, 22.12.2009, p. 59. 

15 

 
 
scope of Appendix C of the Taxonomy’s Climate and Environment Delegated Acts38 39 in 
terms  of  substances  covered.  This  will  significantly  reduce  the  burden  to  demonstrate 
alignment with the Taxonomy and facilitate access to sustainable finance. 

5.2.  Targeted revision of the REACH Regulation  

The Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals 
(REACH)40  is  the  EU’s  cornerstone  legislation  regulating  chemicals.  REACH  has 
contributed to increasing the knowledge on chemicals through registration and evaluation, 
and  to  addressing  the  risk  posed  by  certain  chemicals  through  authorisations  and 
restrictions.  However,  certain  REACH  processes  have  proven  to  be  burdensome  for 
companies, in particular SMEs.  

By  the  end  of  2025,  the  Commission  will  adopt  a  proposal  for  a  targeted  revision  of 
REACH to simplify the rules and speed up the procedures for industry, taking into account 
competitiveness,  safety,  security  and  sustainability  considerations,  while  ensuring  high 
level of protection of human health and the environment41.  

5.3.  The ECHA Regulation 

In  addition,  the  Commission  is  proposing  a  self-standing  Regulation  for  the  European 
Chemicals Agency (ECHA) to enhance its governance and increase the sustainability of 
its  financing  model.  The  aim  is  to  empower  ECHA  to  carry  out  its  expanding 
responsibilities  effectively,  strengthen  ECHA’s  ability  to  deliver  timely  and  coherent 
investment  certainty. 
scientific  opinions,  helping  companies  plan  with  greater 
Simplification of the financing model will enhance ECHA’s operational agility and reduce 
the administrative burden. Improved efficiency will also enable ECHA to provide better 
services to businesses, particularly SMEs, thereby reducing their compliance costs. 

5.4. 

Providing clarity on PFAS  

The scientific assessment of the Universal PFAS42 restriction by the ECHA’s committees 
is ongoing and scheduled to conclude in 2026. The Commission is committed to presenting 

(38)  Commission Delegated Regulation (EU) 2023/2486 of 27 June 2023 supplementing Regulation (EU) 
2020/852 of the European Parliament and of the Council by establishing the technical screening criteria 
for determining the conditions under which an economic activity qualifies as contributing substantially 
to  the  sustainable  use  and  protection  of  water  and  marine  resources,  to  the  transition  to  a  circular 
economy, to pollution prevention and control, or to the protection and restoration of biodiversity and 
ecosystems and for determining whether that economic activity causes no significant harm to any of the 
other environmental objectives and amending Commission Delegated Regulation (EU) 2021/2178 as 
regards specific public disclosures for those economic activities” 

(39)  Commission  Delegated  Regulation  (EU)  2021/2139  of  4  June  2021  supplementing  Regulation  (EU) 
2020/852 of the European Parliament and of the Council by establishing the technical screening criteria 
for determining the conditions under which an economic activity qualifies as contributing substantially 
to climate change mitigation or climate change adaptation and for determining whether that economic 
activity causes no significant harm to any of the other environmental objectives, OJ L 442, 9.12.2021, 
p. 1. 

(40) Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 
concerning  the  Registration,  Evaluation,  Authorisation  and  Restriction  of  Chemicals,  OJ  L  396, 
30.12.2006, p. 1. 

(41)    See also the Defence Readiness Omnibus Communication, COM/2025/820/final, 

(42)  Five  national  authorities  (Denmark,  Germany,  The  Netherlands,  Sweden  and  Norway)  submitted  to 

ECHA in January 2023 a restriction dossier for all PFAS. 

16 

 
 
a proposal as soon as possible after receiving ECHA’s opinion, with the overall objective 
of minimising PFAS emissions.  

The Commission will consider PFAS ban in consumer uses such as cosmetics, food contact 
materials and outdoor clothing. Where adequate alternatives in terms of performance and 
safety  are  not  available,  the  continued  use  of  PFAS  in  industrial  applications  may  be 
allowed  for  critical  applications,  such  as  health,  defence,  semiconductors,  and  other 
strategic  sectors43,  under  strict  conditions  until  acceptable  substitutes  are  found. 
Derogations for uses will need to be accompanied by requirements to reduce emissions at 
all  lifecycle  stages  to  limit  the  release  of  pollutants  into  the  environment  and  by  clear 
incentives to innovate.  

The  Commission  will  support  industry  efforts  towards  mitigation  and  remediation,  to 
achieve  increased  water  resilience,  to  reinforce  Ocean  health44 and  address  pollution of 
water, soil and air. 

To support the transition away from PFAS, the Commission is pursuing a comprehensive 
strategy  that  combines  regulation  with  other  measures.  They  will  include  targeted 
investment  in  research,  innovation  for  safe  and  sustainable  alternatives,  and  enhanced 
coordination  across  EU  institutions  and  Member  States,  expert  networks  to  share 
knowledge  and  solutions.  EU  Innovation  Hubs  will  prioritise  action  to  find  safe  and 
sustainable alternatives to PFAS. 

The  Commission  will  promote  a  shift  from  PFAS  towards  safer  alternatives45.  The  EU 
must take decisive efforts to clean up sites already strongly polluted by such substances. 
Cleanup should be based on the polluter pays principle, with public money allocated to 
clean up orphan sites, where no liable entity could be found. Although remediation efforts 
are very costly, research and innovation can significantly reduce these costs through novel, 
including bio-based, technologies, which will be promoted in the Bioeconomy Strategy.  

A new EU-wide PFAS monitoring framework will be developed to centralise information, 
identify  pollution  hotspots,  highlight  successful  remediation  practices,  and  collect  data 
from relevant legislation. The Commission will explore how to best enhance information 
sharing and communication on PFAS pollution and substitution and will launch a dialogue 
bringing  together  stakeholders  to  support  a  holistic  view  of  PFAS-related  pollution 
challenges. Also, to tackle legacy pollution, the Commission will aim to set up a public-
private  initiative  to  achieve  a  technological  breakthrough  in  feasible  and  affordable 
methods for the detection and remediation of PFAS. 

5.5.  Occupational Safety and Health 

Occupational  safety  and  health  is  essential  not  only  for  protecting  workers'  health  and 
safety but also for boosting productivity, enhancing competitiveness, and ensuring a level 
playing field across industries. This is realised, among others, through the establishment 

(43)   Communication from the Commission Guiding criteria and principles for the essential use concept in 

EU legislation dealing with chemicals (C/2024/2894). 

(44)  See the European Ocean Pact, COM/2025/281 final, p. 8. 

(45)  See also the European Water Resilience Strategy, COM(2025) 280 final, p. 5-6. 

17 

 
 
 
of  occupational  exposure  limits  at  EU  level  under  the  Carcinogens,  Mutagens  and 
Reprotoxic Substances Directive (CMRD)46 and under the Chemical Agents Directive.47  

The Commission will: 

•  Adopt an Omnibus proposal for the Chemical Industry (Q3 2025). 
•  Amend  DNSH  criteria  for  pollution  prevention  and  control  under  the  Taxonomy 

regulation (Q3 2025). 

•  Adopt a proposal for a targeted revision of REACH (Q4 2025). 
•  Adopt a proposal for the ECHA Basic Regulation (Q3 2025). 
•  Adopt  a  simplification  omnibus  on  plant  protection  products  and  accelerate  market 

access for biopesticides (Q4 2025). 

•  Adopt  proposal  to  reduce  administrative  burden  in  environmental  legislation 

(Environmental Omnibus) (Q4 2025). 

•  Propose  a  PFAS  restriction  under  REACH  on  the  basis  of  ECHA’s  opinion  on  the 

‘universal’ PFAS restriction dossier. 

•  Develop an EU-wide PFAS monitoring framework to centralise data as well as promote 
practical, science-based solutions for a sustainable shift by EU industry (Q4 2026). 
•  Launch a dialogue bringing together stakeholders to support a holistic view of PFAS-

pollution related challenges (Q2 2026).  

6.  CONCLUSION  

Successful  implementation  of  this  Action  Plan  will  require  a  concerted  effort  from  all 
stakeholders,  including  the  European  Institutions,  Member  States,  industry,  and  civil 
society. It will be essential to work together to create a favourable business environment, 
to  promote  investment  in  decarbonisation  and  innovation,  to  reduce  the  sector’s 
dependencies, and to provide access to the resources necessary for the transition to a more 
competitive and sustainable future.  

The Commission is committed to working closely with all stakeholders to ensure that this 
Action Plan is implemented effectively and that its objectives are achieved. For this, the 
Comission will maintain close dialogue with stakeholders, monitor results of this Action 
Plan and will ensure its speedy delivery. 

By doing so, we can ensure that the EU chemicals industry continues to play a vital role in 
the  EU's  economy  and  society,  while  also  contributing  to  the  achievement  of  the  EU's 
climate and environmental goals. 

*** 

(46)  Directive 2004/37/EC of the European Parliament and of the Council of 29 April 2004 on the protection 
of  workers  from  the  risks  related  to  exposure  to  carcinogens  or  mutagens  at  work  (Sixth  individual 
Directive within the meaning of Article 16(1) of Council Directive 89/391/EEC), OJ L 158, 30.4.2004. 

(47)  Council Directive 98/24/EC of 7 April 1998 on the protection of the health and safety of workers from 
the  risks  related  to  chemical  agents  at  work  (fourteenth  individual  Directive  within  the  meaning  of 
Article 16(1) of Directive 89/391/EEC), OJ L 131, 5.5.1998, p. 11. 

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