ECHA’s body, the Forum for Exchange of Information on Enforcement (the Forum) has adopted its work programme for 2026-2027 regarding the compliance of chemical products within the European Union and the European Economic Area.
This strategic roadmap is designed to protect human health and the environment by ensuring that chemical regulations such as REACH, CLP, POPs, PIC and BPR are applied consistently across the EU/EEA. With the Chemicals Strategy for Sustainability (CSS) calling for “zero tolerance” toward non-compliance, the Forum is shifting its focus toward high-risk areas including imports and online marketplaces.
One of the pillars of the REACH Regulation’s revision is enforcement.
Through its actions, the Forum and the BPRS put ECHA’s priorities into practice. The work programme is fully aligned with the ECHA Strategy Statement 2024-2028, where priorities and goals are identified.
According to ECHA’s previous enforcement, up to 64% of imported products checked were non-compliant with CLP labelling requirements and up to 17% were non-compliant with REACH restrictions.
How ECHA aims to Improve Compliance?
To address this, the Forum and BPRS will be guided by practical enforcement and swiftly addressing political and regulatory developments, such as the need to work closely with customs, control online sales or advise on the enforceability of important new restrictions.
Regular training for inspectors continues. The Forum and BPRS have provided annual training courses for law enforcement trainers and inspectors. Each year, they provide direct training to several hundred inspectors.
It is crucial to continue improving cooperation through the involvement of industry and stakeholders. This can be done through dedicated sessions or workshops to communicate the results of application projects and discuss recommendations for industry.
Critical methodologies for Chemical Compliance
The Forum plans to enhance compliance levels through a set of key actions, spanning both horizontal and sector-specific priorities:
Horizontal priorities:
- Tightening Control of Imports: due to previous enforcement projects revealing crucial compliance gaps.
Moreover, a recent EU-wide REF-12 project found that registration was missing for 32% of substances in imported mixtures and 7% of substances imported on their own.
The Forum will prioritize actions to improve the oversight of imported mixtures and articles. - Targeting Online Sales: past findings detected that 3 out of 4 online products failed to comply.
The Forum will prioritize controls and will harmonize approaches to enforce regulatory compliance in online sales of chemicals; this also includes the use of legislation like the Digital Services Act or the General Product Safety Regulation. - Implementing Integrated Enforcement: to maximize limited resources, inspectors will be encouraged to check products against multiple pieces of legislation simultaneously (e.g., checking an article for both REACH and POP Regulation compliance) developing cross-legislation cooperation with other inspection services.
- Enhancing Inter-Authority Cooperation: The Forum will foster closer ties with customs authorities and other enforcement networks like IMPEL and SLIC CHEM to streamline cross-border controls.
Specific priorities:
- Prioritizing Substances of Concern: Enforcement will focus heavily on regulatory risk management measures, such as REACH Authorizations and Restrictions, to ensure the most hazardous chemicals are handled correctly.
- Prioritizing actions on harmonizing classification and correct hazard communication (REF-14 project).
- Deploying Rapid Enforcement Initiatives: Beyond long-term projects, the Forum will explore quick-response initiatives to address emerging or urgent compliance issues as they arise in the market.
Within 2026 and 2027 there will be more controls over product’s compliance in the European Union.
In this time, ensuring to be compliant with regulations such as REACH, CLP and BPR is crucial for manufacturers and importers to avoid sanctions.
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