Fourth ECHA report: progress and challenges for the REACH and CLP system

CHA has published its fourth report on the implementation of the REACH and CLP Regulations, covering the 2021–2025 period. The findings highlight significant progress in achieving the objectives of protecting human health and the environment while maintaining the competitiveness of European industry.

One of the most significant developments over the five-year period is the transition to a group-based assessment approach, under which structurally similar substances are evaluated together rather than individually. This shift moves away from the traditional case-by-case assessment model, enabling faster identification of substances requiring regulatory action. Supporting this transformation, ECHA has undertaken a major digitalisation programme, culminating in the launch of ECHA CHEM in 2024, a new database that has significantly improved the transparency and accessibility of REACH and CLP data. By 2025, the migration of the entire Classification and Labelling Inventory had also been completed. In parallel, the 2024 revision of the CLP Regulation introduced new hazard classes for endocrine disruptors (EDs), persistent, bioaccumulative and toxic substances (PBT/vPvB), and persistent, mobile and toxic / very persistent and very mobile substances (PMT/vPvM), further strengthening hazard communication throughout the supply chain.

The report also highlights several important challenges. Notably, 16% of active registrations have not been updated in the last ten years, reducing their alignment with the latest scientific knowledge. In addition, ECHA's scientific committees, the Committee for Risk Assessment (RAC) and the Committee for Socio-economic Analysis (SEAC), are facing increasing pressure due to the growing complexity and volume of regulatory dossiers, underlining the need for structural improvements and greater operational efficiency. Nanomaterials also remain an area of concern: despite the information requirements introduced in 2020, available (eco)toxicological data remain insufficient, indicating that industry has not yet fully complied with the applicable regulatory requirements.

From an enforcement perspective, the findings confirm the need for continued vigilance. More than 20,000 inspections coordinated by the Forum for Exchange of Information on Enforcement identified a 32% non-compliance rate for substances imported in mixtures. At the same time, the transition to the harmonised Poison Centres Notification (PCN) system has been successfully completed, with approximately 12 million notifications submitted, providing essential information for emergency health response.

Looking ahead, ECHA adopted a new organisational structure on 1 March 2026 to support an increasingly broad regulatory mandate that now extends well beyond the original scope of the REACH and CLP Regulations.

For companies, the message is clear: keeping registration dossiers up to date, continuously monitoring the compliance status of substances, and ensuring effective information management throughout the supply chain will become increasingly critical. In an increasingly digitalised and integrated regulatory environment, the ability to maintain high-quality data and rapidly adapt to regulatory developments will be a key factor in ensuring effective risk management and business continuity within the European market.