ECHA Programme 2026-2028: New EU Chemicals Legislation

In early January 2026, the European Chemicals Agency (ECHA) published its “Single Programming Document” for 2026-2028, a document that sets the priorities, projects and development directions of European chemicals legislation for the next three years. Behind 134 pages of technical text lies a practical guide: what is coming, where enforcement will focus, and which requirements will soon become reality for companies.

For Serbian manufacturers, importers and exporters of chemicals, however, this document is not academic material; it is an announcement of what lies ahead. Those who export to the EU must meet new requirements as soon as they enter into force, regardless of when Serbia transposes them into national legislation. And those who sell only in Serbia can expect the same requirements to arrive with the usual delay of 12 to 18 months.

Let us look at what the ECHA programme reveals and what it concretely means for business over the next three years.

New legislation on the horizon

The ECHA Programming Document identifies seven key legislative areas at different stages of development, from Commission proposals still expected, through those already in the legislative procedure, to those where ECHA has already started preparing for implementation.

Common Data Platform on Chemicals is perhaps the most significant change in how chemicals data will be managed at EU level. The centralised platform will bring data from the ECHA, EFSA (European Food Safety Authority), EMA (European Medicines Agency) and EEA (European Environment Agency) databases together in one place. The goal is a “One Substance, One Assessment” approach: the same substance should not be assessed several times under different laws, but should have a single, comprehensive assessment. According to the plan, ECHA is preparing for implementation during 2026, with a focus on the governance structure and technical requirements.

Directives for the protection of health and the environment

Drinking Water Directive (Article 11) introduces a positive list of materials approved for contact with drinking water. ECHA has already set up a system for receiving notifications, which becomes operational at the end of 2026. From 2027, applications for approval of materials will be accepted. As a result, manufacturers of materials that come into contact with water (pipes, seals, coatings, adhesives) will have to demonstrate compliance with specific requirements and go through a formal approval procedure.

Batteries Regulation tasks ECHA with finalising a study that identifies hazardous substances in batteries and in their manufacture. After the study, the Commission may then ask ECHA to prepare a restriction proposal. The study will be completed in 2026, which means that discussions on possible restrictions may begin as early as 2027.

Packaging and Packaging Waste Regulation likewise tasks ECHA with a study of hazardous substances in packaging and packaging waste. As with batteries, after the study the Commission may request restriction proposals. This directly affects all packaging manufacturers and companies that place packaged products on the market.

Directives for water and electronics

Water Framework, Groundwater and Environmental Quality Standards (EQS) Directives are being amended in ways that give ECHA the task of drawing up watch lists for surface water and groundwater, priority lists, EU environmental quality standards and threshold values for groundwater. ECHA is also setting up a repository of national EQS values.

RoHS Directive (Restriction of Hazardous Substances in electrical and electronic equipment) extends ECHA’s mandate. Starting in 2026, ECHA will begin preparing a review of substances that will result in possible restriction proposals after a transitional period. From 2027, ECHA will start assessing requests for exemptions from the ban on certain substances in electrical and electronic equipment.

In addition, the End-of-Life Vehicles (ELV) Regulation and the Medical Devices Regulation also assign new tasks to ECHA, although these are still at earlier stages of preparation.

KEY TAKEAWAYS

Seven new legislative areas are at different stages:

Common Data Platform: implementation starts in 2026.
Drinking Water Directive: applications from 2027.
Batteries & Packaging studies: completion in 2026.
EU digital platforms remain EU infrastructure; Serbia potentially transposes the legislation

REACH, CLP and BPR: Priorities for 2026-2028

While new legislation brings new tasks, ECHA is at the same time strengthening enforcement of existing legislation and clearing the backlog of cases that has built up.

Biocidal products and the assessment of endocrine disruptors

Biocides Review Programme is getting accelerated treatment. In particular, ECHA is focusing on the assessment of the properties of active substances that act as endocrine disruptors. ECHA is stepping up its support to national competent authorities in the assessment process through dedicated technical support, early informal consultations and compliance checks for all assessments. Coordination with EFSA is being intensified through six scheduled meetings a year in order to improve the alignment of assessments of shared substances in line with the “One Substance, One Assessment” approach.

Dossier evaluation and clearing the backlog

Dossier evaluation is undergoing major process changes. For testing proposals, ECHA is carrying out a comprehensive process review during 2026 with the aim of reaching a steady state in which the backlog is minimal. The target number of draft decisions on testing proposals for 2026 is 50, with a plan to improve process efficiency significantly.

Compliance checks are focusing on quality rather than quantity. Specifically, the planned number is 100 checks for 2026, which is a reduction compared with 251 in 2024 and 200 in 2025. The reason: a shift to targeted checks instead of a broad approach, plus a greater emphasis on the follow-up process, where there is currently a large backlog.

In this context, ECHA is applying a new approach with the aim of eliminating the backlog within five years and reaching a steady state in which open cases stay close to zero. The target is 150 follow-up decisions in 2026. ECHA is also strengthening coordination with national enforcement authorities through the Forum for Exchange of Information on Enforcement, with dedicated training and better monitoring of enforcement activities.

Coordination and system modernisation

The One Substance, One Assessment expert group continues working on better prioritisation and coordination of activities across different laws. ECHA, the Commission, the Member States and other EU agencies use this framework to identify substances or groups of substances that require harmonised classification, restrictions or other risk management measures.

IT system modernisation and exploring the use of artificial intelligence are also priorities. ECHA is developing a single portal for industry with the aim of reducing the administrative burden on companies by consolidating submission processes. The “ECHA CHEM” platform is becoming the central access point for the data ECHA holds, paving the way for the future “Common Data Platform on Chemicals”. The agency is also exploring opportunities to apply artificial intelligence in its processes.

NUMBERS THAT TELL THE STORY

Decisions on testing proposals: 50 in 2026 (process review under way)
Compliance checks: 100 in 2026 (down from 251 in 2024)
Follow-up decisions: 150 in 2026 (goal: eliminate the backlog within 5 years)
ECHA-EFSA meetings: 6 a year (stronger coordination)

What this means for Serbian companies

Exporters to the EU: Immediate compliance requirements

Companies that export to the EU do not have the luxury of waiting for national transposition. As soon as new requirements enter into force in the EU, products entering the EU market must comply.

Biocidal products: the stepped-up assessment of endocrine disruptors may mean that active substances currently under review will become subject to restrictions or will require additional data. Biocide manufacturers should already be reviewing their formulations and following the results of the ECHA review programme.

Manufacturers of materials that come into contact with water (valves, pipes, seals, tank coatings): the “Drinking Water Directive” brings an entirely new approval regime. Notifications start at the end of 2026, applications in 2027. Preparing documentation, testing and the submission procedure are not quick, so manufacturers should start preparing now if they plan to stay on the EU market.

Manufacturers or importers of batteries and packaging: ECHA’s studies in 2026 will identify which hazardous substances are of concern. At the same time, while restriction proposals may come later, the smart move is to anticipate what will be flagged as problematic and to start considering alternatives already.

Domestic manufacturers: The harmonisation window

Serbia harmonises its legislation with the EU through the Stabilisation and Association Agreement. In practice, the average delay between adoption in the EU and Serbian transposition is 12 to 18 months, sometimes longer for complex legislation.

It is important to understand the difference: Serbia transposes the rules (what is prohibited, how things are classified, which labels are required) but does not build parallel digital systems. The “Common Data Platform” and ECHA CHEM remain EU infrastructure that Serbian companies can access when they need to.

For companies that sell exclusively in Serbia, this means a window of two to three years before compliance becomes mandatory. Using this period to prepare is a strategic advantage. Waiting for the rule to enter into force means reacting under pressure, often at higher cost and with hasty decisions.

Concrete steps, now

CHECKLIST FOR YOUR COMPANY

☐ Are your chemicals data digitalised and structured?
☐ Do your formulations contain endocrine disruptors?
☐ Do you know the composition of materials throughout the supply chain?
☐ Does your EHS team follow EU regulatory developments?

Four key areas that need attention:

Digitalisation of chemicals data. Modern requirements are hard to meet with data held in Word or PDF formats. For example, companies that already use digital chemicals management systems have structured data that can easily be exported in different formats, linked to EU systems when needed, and quickly updated when the rules change. Moving to modern chemicals data management systems is no longer optional; it is a precondition for sustainable compliance.

Review of endocrine disruptors. ECHA is sharpening its focus on these substances through the “Biocides Review Programme”. So review your formulations: do they contain known or suspected endocrine disruptors? What are the possible substitutes? Having a plan now is better than urgently searching for alternatives once a restriction proposal comes out.

Supply chain transparency. In addition, new rules require better knowledge of materials and substances throughout the supply chain. Check: do your suppliers follow developments in EU legislation? Do you have insight into the composition of the materials you buy? If not, this is a warning sign.

Strengthening internal capacity. EHS teams need training on the new requirements. A single “Programming Document” reveals seven different legislative directions; sustainable compliance requires the capacity to follow developments, interpret requirements and apply them at the operational level.

Strategic implications

Three broader trends emerge from the ECHA “Programming Document”.

First: Data is becoming a competitive advantage, not just a compliance requirement. Companies with digital infrastructure for chemicals management adapt faster, can access the “Common Data Platform” when they need to, and become preferred partners in the supply chain. Those who still manage safety data sheets and chemicals data manually, on the other hand, experience every new requirement as a burden rather than an opportunity.

Second: Group regulation is becoming the standard approach. Moreover, ECHA is placing more and more focus on groups of substances instead of individual chemicals: PFAS restrictions, microplastics, endocrine disruptors as a class. This means that tracking only the substance you currently use is not enough; you need to understand the whole group and anticipate what is coming.

Third: Enforcement is getting stronger and the backlog is being cleared. Finally, follow-up after dossier evaluation decisions is becoming a priority, coordination with national enforcement authorities is being strengthened through the Forum, and the backlog of testing proposals is being aggressively cleared. The room for non-compliance is shrinking.

Conclusion

The ECHA “Programming Document 2026-2028” is not an internal agency document; it is a public guide to EU chemicals regulation for the next three years. Seven new legislative areas, enforcement refocused on clearing the backlog, digital transformation through the “Common Data Platform” and ECHA CHEM, and a systemic shift towards group regulation instead of a substance-by-substance approach.

For Serbian companies, the message is clear: those who understand these priorities can plan their strategy, invest in the right infrastructure and be ready when the new rules enter into force. Those who wait for official transposition into national legislation risk being caught unprepared.

This is the first in a series of detailed analyses of the ECHA “Programming Document 2026-2028”. In the coming weeks, I will analyse each of these areas in depth: the “Common Data Platform on Chemicals”, the “Drinking Water Directive” requirements, the priorities of the “Biocides Review Programme” and other key topics.

Follow the Vetren blog for detailed analyses of how the new rules are being put into practice.

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This blog post is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed chemical adviser or a lawyer specialising in chemical regulation.