REACH reform may be on hold, but product leadership is not
In late April 2026, the European Commission confirmed that it does not intend at this point to proceed with a full revision of REACH (the European Union’s flagship regulation on chemicals), despite having announced such a reform under the 2020 Chemicals Strategy for Sustainability.
The revision was meant to modernise how the EU identifies and manages harmful chemicals and to better align chemicals policy with circular economy goals. While discussions on enforcement or targeted updates may continue, the decision makes one thing clear for product manufacturers: stronger chemicals policy will not arrive on a single, predictable legislative timeline.
A reality shaped by pressure and complexity
Civil society analyses have documented sustained resistance to the proposed REACH revision throughout 2025, particularly around measures that would have strengthened chemical risk management and accelerated the removal of harmful substances from consumer products. An investigation by Corporate Europe Observatory shows that, during this period, senior EU officials met far more frequently with industry actors than with NGOs on the revision, alongside opposition to key technical elements of reform such as polymers, combined chemical exposure, and faster precautionary action.
Regardless of political interpretation, the outcome is clear: progress on strengthening EU chemicals rules has been slow and contested, while hazardous substances continue to circulate in products and materials.
Why waiting for regulation is a risky strategy
For companies placing products on the market, regulatory delay does not eliminate risk. Hazardous substances can still enter products and material loops, contaminate recycling streams, and expose consumers and workers, while reliance on banned lists and minimum compliance fails to prevent regrettable substitution. At the same time, expectations from brands, retailers, investors and public buyers are moving faster than regulation, with growing demand for credible proof of safe, transparent and circular product design.
Cradle to Cradle Certified®: a product‑level answer to a systemic gap
This is where product‑level frameworks become essential. Cradle to Cradle Certified® was designed to bridge the gap between minimum legal compliance and what is needed for genuinely healthy and circular products. The standard works independently of political cycles and assesses products based on what can be demonstrated scientifically.
In particular:
Material Health requirements assess product ingredients and actively restrict classes of chemicals known to be problematic for health and circularity, including PFAS and other organohalogens.
Class‑based approaches reduce the risk of regrettable substitution, an issue that remains central to debates around EU chemicals policy.
Product Circularity requirements recognise that toxic materials undermine reuse and recycling, making chemical safety a precondition for a circular economy, not an optional add‑on.
Independent verification ensures that claims are based on assessment and not assumption.
With Cradle to Cradle Certified® Version 5.0 now in effect, companies have access to an up‑to‑date framework that aligns with the direction of EU sustainability objectives, even in the absence of comprehensive regulatory reform.
Acting now, responsibly
Public regulation remains essential, but when legislative progress slows, credible, third‑party verified action becomes even more important. For companies committed to long‑term competitiveness and credibility, the question is no longer whether regulation will eventually change, but whether their products are already designed to meet the expectations of a healthier, circular economy.
At the Cradle to Cradle Products Innovation Institute, we encourage companies not to wait for the next regulatory cycle to prove leadership. Cradle to Cradle Certified® offers a concrete, science‑based pathway to demonstrate that products are designed for health, circularity and future resilience: starting now!
Source: