2026: Five regulatory decisions that will define the next decade

Mapping the key changes in European chemicals regulation

ChemSec (International Chemical Secretariat) has published its annual “Policy Watchlist” – an overview of the five most important regulatory processes that will unfold during 2026. Unlike the usual announcements, these topics are not administrative amendments to regulations. Each represents a key decision that will set the direction of European chemicals regulation for the next decade.

For companies doing business with the EU market, whether through exports, imports of raw materials or participation in the supply chain, this is not side news. Through the harmonisation process, some of these changes become part of the Serbian regulatory framework within 12-24 months. Understanding these processes enables proactive planning instead of reactive adjustment.

1. REACH revision: When will it finally be published and what to expect

The European Commission did not publish a proposal for the revision of the REACH Regulation during 2025, despite its plans. Publication is now announced for “sometime during 2026”.

What delayed publication:

The Regulatory Scrutiny Board (RSB) gave a negative opinion after internal impact assessments. This is a procedural mechanism that asks for additional explanation or refinement of a proposal when the impact analysis is judged inadequate.

What the revision is supposed to solve in the first place:

The REACH Regulation has been in force since 2007. Over almost two decades of application, numerous practical challenges have been identified:

Procedural complexity of registration
Length of the substance evaluation process
Inconsistency between different parts of the regulation
The question of nanomaterials and complex substances
Compliance costs vs. effectiveness of protection

The revision should balance these issues between the need to protect health and the environment on the one hand, and operational feasibility for industry on the other.

Practical implications for companies:

Any change to REACH directly affects:

Registration obligations – who must, what must, by when
Documentation requirements – what information about the substance
Potentially new restrictions – which substances, which uses
Compliance costs – direct and administrative

Specifically for Serbia:

Our regulatory system strives to follow EU standards, but with specific characteristics.

However, it is important to understand:

Selective implementation: We do not implement all EU changes with the same intensity or speed. The nature of the changes and institutional and infrastructure readiness determine whether, and to what extent, a given change will be implemented in Serbia.

Exporters are not exempt: Even if domestic regulation does not follow a particular EU change, companies exporting to the EU are directly subject to EU requirements. Regulatory delay in Serbia does not release you from obligations towards EU customers.

How to prepare:

Follow the publication of the draft proposal (expected during 2026)
Identify which substances in your portfolio could be affected
Talk to suppliers about their plans
Don’t wait for the final text – start the analysis as soon as the draft comes out
For exporters: follow EU requirements directly

2. PFAS restriction: ECHA opinion by the end of the year

ECHA will publish its final scientific opinion on the proposed PFAS restriction by the end of 2026. This will be followed by a political process in the European Commission that will make the final decision.

What PFAS are and why they are a topic:

Per- and polyfluoroalkyl substances (PFAS) are a large group of compounds containing carbon-fluorine bonds. Characteristics:

Extreme chemical stability (hence “forever chemicals”)
Wide use in industry and everyday products
Bioaccumulation and long-term presence in the environment
Growing scientific consensus on their harmfulness

The central question in the debate:

How to structure the restriction? There are two basic approaches:

Approach A – Comprehensive restriction:

Ban on the whole PFAS group with limited exemptions
Clarity for industry – black or white
Stimulating innovation towards non-PFAS alternatives
Simpler implementation

Approach B – Sectoral restriction:

Different rules for different industries
Exemptions for “critical uses”
Gradual phase-out at different paces
More flexibility, but also more administrative complexity

ECHA’s opinion will analyse the scientific basis for both options. The political decision is made later.

Practical implications:

PFAS are used in:

Water- and grease-repellent treatments (textiles, paper)
Electroplating and surface treatment of metals
Certain fluorescent polymers
Firefighting foams
Specific industrial processes

For companies:

Identify whether your products or processes involve PFAS:

Checking the composition of raw materials with suppliers
Analysis of finished products
Mapping alternatives (even if the ban does not come quickly)

Market reality:

BASF (the largest chemical producer in the world) has announced its exit from PFAS by 2028. So has Ecolab. This shows that industry is not waiting for final regulation – decisions are being made now.

For exporters to the EU: demand for non-PFAS alternatives is growing not only because of regulation, but also for reputational reasons and supply chain requirements.

3. Circular Economy Act: Balancing recycling and material quality

Adoption of the Circular Economy Act is planned for late 2026. The goal: creating a single market for secondary raw materials and raising the quality of recycled materials.

The basic premise:

Circular economy means keeping materials in use for as long as possible through:

Designing products for durability
Easier repair and maintenance
Efficient recycling at end of life
Returning materials to the production cycle

The technical challenge:

When you recycle materials, you recycle everything in them – including hazardous substances that may have been added years earlier. For example:

Plastics with brominated flame retardants
PFAS-treated textiles
Electronics with heavy metals

Recycling in itself does not destroy these substances – it returns them to the system.

Two possible scenarios:

Scenario 1 – Controlled circular economy:

Clear standards on which materials can go into recycling
Mandatory testing of secondary raw materials
Transparency about what is in recycled materials
Tracking product composition through the life cycle

Scenario 2 – Uncontrolled circular economy:

Focus on quantity, not quality of recycling
Hazardous substances circulate through the system indefinitely
Less transparency, more risk

For industry:

The Circular Economy Act will very likely include:

Requirements for information on product composition
Standards for recycled materials
Possible restriction of certain substances in products intended for recycling

An important reminder – the Digital Product Passport:

The concept of the Digital Product Passport (DPP), already mentioned in the context of the upcoming detergents regulation (I wrote about it a few weeks ago), is a mechanism for tracking the composition and history of a product. This approach could become a broader instrument for implementing circular economy goals, enabling transparency about which substances are present in materials intended for recycling.

How to prepare:

Document what goes into your products (now, not when the requirements become mandatory)
Talk to suppliers about the composition of their materials
Assess whether your products can meet future recycling standards

4. Cosmetics omnibus: Alignment with the Chemicals Strategy for Sustainability

We expect the final negotiations between member states and the European Parliament on the cosmetics omnibus during 2026.

What the omnibus is:

It is not a new regulation, but a process of aligning the existing Cosmetics Regulation with the broader goals of the Chemical Strategy for Sustainability (CSS). The CSS sets ambitious goals for reducing exposure to hazardous chemicals.

What makes cosmetics specific:

Cosmetics is a sector where people are directly exposed to chemicals through the product – application to the skin, face, lips. That is why the question of composition is especially sensitive.

Currently, cosmetics regulation has numerous exemptions and longer transition periods for certain substances compared to other sectors.

Key questions in the negotiations:

Scope of restrictions – which substances, which concentrations
Transition periods – how much time industry has to adapt
Exemptions – whether, and for which specific uses

CMR substances in cosmetics:

Carcinogens, mutagens and reproductive toxicants (CMR) are a class of substances with the strictest restrictions in most sectors. In cosmetics the situation is not always so clear.

The omnibus should clarify:

Whether CMR substances may remain in cosmetics
Under which conditions
With which timeframes for phasing out their use

For cosmetics manufacturers:

This is a sector where consumer awareness is exceptionally high. Even if the regulation turns out milder than some expect, market pressure may be stronger.

Consumers are increasingly insisting on:

Transparency about ingredients
Absence of controversial substances
“Clean beauty” formulations

Exports to the EU:

The final text of the omnibus will become the standard for everyone who wants to place cosmetics on the EU market. Better to be ahead of the requirements than to chase them.

5. Market shifts: BASF and the exit from PFAS production

BASF, the largest chemical producer in the world, has announced a complete exit from PFAS production by 2028. Ecolab has announced something similar. These are not isolated events – they are an indicator of a wider trend.

Why this is relevant:

When a global leader makes a decision like this, it triggers a cascade effect through the supply chain:

Companies further down the chain (customers of BASF’s PFAS) have to find alternatives
Those alternatives have to be validated, tested and industrialised
Smaller companies in the chain have to follow or be left without a supplier
Entire supply chains are reorganised

And all of this is happening before the EU Commission adopts the final PFAS restriction.

What drives these decisions:

It is not just anticipation of regulation. It is a combination of factors:

Reputational risk – public perception of PFAS is becoming negative
ESG criteria – investors are asking for an exit from problematic substances
Liability insurance – insurance for PFAS is harder to get
Litigation risk – a growing number of court cases related to PFAS
Customer requirements – large companies are demanding PFAS-free supply chains

The message:

The market often moves faster than regulation. Relying only on “what is currently legally allowed” can be a short-sighted strategy.

For the supply chain:

If you are part of a chain that involves PFAS:

Mapping exactly where in your processes/products PFAS are
Talking to suppliers about their plans
Researching alternatives
Pilot testing of non-PFAS solutions

Don’t wait for a customer or supplier to give you an ultimatum. Proactively managing these changes gives you time for quality decisions.

Harmonisation and regulatory lag: What this means for Serbia

Serbia operates in a system that in practice follows EU regulation with a certain time gap. This “regulatory lag” is not a technical error – it is the reality of the harmonisation process and institutional readiness.

Selective implementation:

It is important to understand that we do not implement all EU changes with the same intensity or speed. The nature of the changes, their complexity, institutional capacity and infrastructure readiness determine whether, and to what extent, a given change will be implemented in the domestic regulatory framework.

For exporters to the EU:

However, this does not release exporters from their obligations. Each of these five changes directly affects export conditions:

REACH revision → documentation requirements
PFAS restriction → possible products
Circular Economy Act → transparency about composition
Cosmetics omnibus → standards for cosmetics
Market shifts → supply chain requirements

EU customers are already setting requirements that anticipate future regulation. “Currently allowed in Serbia” is not always enough for export.

For local manufacturers:

Even without direct exports, changes in the EU are reflected through:

Raw materials – what is available and at what price
Suppliers – their new standards
Documentation – what customers ask for
Domestic regulation – which eventually follows

The advantage of a proactive approach:

Companies that wait for domestic regulation to “catch up” with the EU often find themselves having to adapt urgently. Those who follow EU processes early have time for:

Analysing the impact on their specific portfolio
Testing alternative solutions
A gradual transition instead of a sudden leap
Using the EU transition period for their own preparation

Conclusion: Compliance as a competitive advantage

The five decisions to be made during 2026 are not just regulatory changes. They are strategic crossroads that set the direction of industry for the next decade.

Key takeaways:

REACH revision – Follow the draft as soon as it comes out, don’t wait for the final text

PFAS restriction – ECHA opinion by the end of the year, but the market is already moving

Circular Economy Act – Transparency about composition is becoming unavoidable

Cosmetics omnibus – Consumer pressure may be stronger than regulation

Market shifts – Supply chains are being reorganised before regulation enters into force

For companies doing business with the EU:

Regulatory changes are not a threat – they are information. Companies that understand them as strategic information, rather than a compliance burden, have a competitive advantage.

Following these processes is not about whether you support certain regulations or not. It is about understanding how the market is changing and how to position yourself accordingly.

2026 is the year of strategic positioning.

Links:

ChemSec Policy Watchlist 2026: https://chemsec.org/policy-watchlist-the-biggest-news-well-be-following-in-2026/

BLOG: The new EU regulation on detergents and surfactants: https://vetren.rs/nova-eu-regulativa-deterdzenti-2026-dpp-zahtevi-za-usaglasavanje/

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.