IVL Swedish Environmental Research Institute

The EU chemicals legislation, with the REACH and CLP regulations as its cornerstones, plays an important role in reducing exposure to substances of very high concern and driving substitution. At the same time, there is concern about how current and upcoming regulations affect companies’ capacity for innovation, competitiveness, and their ability to phase out hazardous substances effectively. The purpose of this project has been to gain a deeper understanding of how chemicals legislation influences companies’ competitiveness and their work with substitution.

The study combines a literature review with an interview study, in which individuals working with regulatory compliance and chemicals management in practice were interviewed. The literature shows that regulation through legislation has led to reduced use of several substances of very high concern (SVHC) substances and contributed to substitution towards less hazardous alternatives. At the same time, insufficient harmonisation between regulatory frameworks, complex processes, e.g. for reporting, and limited resources are highlighted as significant obstacles. Several studies also emphasise the risk of “regrettable substitution” if the focus lies on individual substances instead of considering alternatives from a broader perspective that accounts for function and overall life-cycle risk. The interviews confirm that legislation is perceived as an important driver for phase-out, but also as administratively burdensome and sometimes unclear. Companies describe challenges related to short transition periods, unpredictable regulatory processes, differing definitions between legal acts, and a lack of transparency in the supply chain.

Global differences in requirements and costs are perceived to affect competitiveness, particularly when EU-based companies operate on the same markets as actors subject to less stringent regulations. At the same time, both literature and interviews show that regulation can stimulate innovation, especially when combined with clear time horizons, increased transparency, and access to tools and guidance for substitution. Several companies already conduct proactive substitution work, often driven by internal sustainability goals and customer requirements. The report concludes with recommendations on how chemicals legislation can be better designed and implemented to simultaneously strengthen the protection of human health and the environment and promote the development of safe and sustainable products. Key proposals include increased harmonisation and coordination between regulatory frameworks, improved predictability and transparency, more efficient information flows in the value chain, and enhanced support and dialogue between authorities, industry, and research.