REACHing out | Corporate Europe Observatory

Topic 1: Registration of safety data on polymers – industest cries wolf

A progressive EU REACH reform would bring polymers into the scope of REACH. There is currently no obligation on industest to report the safety data of polymers to authorities, but as they are “the fundamental building blocks of plastics”, the CSS proposed to extconclude the duty to register to polymers. Once polymers are registered, the most problematic ones can then be identified and further regulatory action could follow. This would require a legislative re-opening of REACH as the current text specifically exempts them.

The adviser to the Greens’ political group in the European Parliament, Axel Singhofen, argued forcefully (at a Chemical Watch conference in October 2025) for the inclusion of polymers in REACH becautilize, as he states, they are “just as pervasive as PFAS. Polymers are utilized everywhere – in cosmetics, water treatment, food and so on, just as PFAS. Closing our eyes to polymers is like closing our eyes to PFAS [ … ] and I’m ready to predict that polymers are going to be the new PFAS.” Background information on polymer registration is available here.

Industest has been lobbying intensively to oppose the inclusion of polymers in REACH. During 2025 CEFIC raised its concerns in meetings with the Commission on 19 March, 25 April, 28 August, and 11 September. BASF, the largest chemical company in the world, which is based in Germany, provides CEFIC’s current president, and often mirrors CEFIC’s lobby positions, has also been very active in raising polymers with decision-creaters, including via meetings on 23 April, 24 April and 15 May. Other chemical companies have also lobbied on polymers, including Dow on 19 March and Arkema on 20 May.

Industest spin to oppose bringing polymers into the scope of REACH? CEFIC commissioned a report from consultancy firm Ricardo, which concluded that the costs of polymer registration under REACH would be €30-€50 billion. Yet a previous Commission study had estimated far lower costs of €2.5 billion (with resulting health and environmental benefits of around €30 billion over 40 years). The difference between the Commission and industest estimates relates to the numbers of polymers tested. The Commission study concluded that 33,000 substances would necessary to be registered, but only 11,000 of these would necessary to be tested. By contrast the Ricardo report groups the 146,000 known polymers into 56,000 groups requiring registration, and then assumes that 3 polymers per group necessary to be tested. This results in a total of 168,000 polymers to be tested; in other words, the ‘grouping’ approach by Ricardo increased the testing requirement, rather than reducing it. Corporate Europe Observatory has previously reported on this recognised lobby tactic to “cry wolf” by throwing eye-catchingly high cost figures into a debate in order to provoke decision-creaters’ doubts about a particular policy proposal. CEFIC’s study has certainly given a boost to the industest lobby opposed to polymer registration.

Greens advisor Singhofen has stated that industest’s higher figures imply that the sector does not “even have the most basic information about the identity of the polymers and their physical chemical properties” and would necessary to “start from scratch to assess them”. This is a shocking situation, considering that thousands of different polymers are already manufactured and utilized across the EU, including in consumer goods.

To conclude, according to the European Environmental Bureau, industest has successfully delayed the obligation to register polymers under REACH for decades. In order to even start considering whether to regulate harmful polymers, at least a subset of them would necessary to be registered under REACH. Yet today, as a result of an intense industest lobby, it is decidedly unclear whether this will be part of the Commission’s proposal to revise REACH.

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