Europe needs measurable regulatory impact, not simply more administrative workload.

The ECHA report on the implementation of REACH and CLP in 2026 describes a highly active regulatory system. For the period 2021 to 2025, the report refers, among other figures, to 18,911 initial registrations, 45,189 dossier updates, 1,528 compliance checks, 161 substance evaluations, 6,745 additional information requests, 44 new entries on the Candidate List and 202 newly added or amended harmonised classifications in Annex VI to the CLP Regulation.

These figures demonstrate substantial administrative and assessment activity. However, they do not answer the key question of whether REACH is achieving its political objectives more effectively in measurable terms: the protection of human health and the environment, the functioning of the internal market and the strengthening of competitiveness and innovation in Europe.

From the perspective of CETS, regulatory success cannot be assessed primarily by counting procedures, dossiers and substances. What matters is whether exposures have measurably decreased, diseases have been prevented, emissions have been reduced or environmental conditions have demonstrably improved. The report provides limited evidence on such outcome-based indicators.

The number of new substances is also not, in itself, a robust indicator of innovation. The report refers to an average of 361 new substances per year during the reporting period and states that this is broadly in line with the level before the 2018 registration peak. This does not demonstrate that REACH has improved or accelerated innovation compared with the period before REACH. New substances are driven primarily by market demand, technical requirements and industrial applications – not simply by the existence of a registration regime.

Fair competition is another key issue for European manufacturers and downstream users. While imported substances are covered by registration obligations, imported articles are not systematically subject to equivalent controls. The fact that non-compliance with registration duties for imported substances in mixtures was found to be 32% in the latest project points to the need for more effective enforcement at the actual points of risk.

CETS supports modern and effective chemicals regulation. However, the further development of REACH should be more risk-based, better prioritised and aligned with measurable outcomes. More procedures alone do not automatically deliver a higher level of protection – nor do they strengthen Europe’s industrial base.

Source: ECHA, Report on the operation of REACH and CLP 2026.