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May 2, 2022

EC Publishes Restrictions Roadmap, Prioritizing Group Restrictions for the Most Harmful Chemical Substances


On April 25, 2022, the European Commission (EC) published a Restrictions Roadmap under the Chemicals Strategy for Sustainability (Restrictions Roadmap) that provides detailed information on all ongoing work on future restrictions under the European Union (EU) chemical legislation. The Restrictions Roadmap prioritizes group restrictions for the most harmful substances to human health and the environment, as set out in the Chemicals Strategy for Sustainability (Strategy). According to the EC’s press release, the Restrictions Roadmap includes a rolling list (Rolling List) of substances that will become the basis for the multiannual planning under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation. The EC states that it will regularly review and update the Rolling List to ensure a balance between needed flexibility and commitment to ensure progress.

The EC notes that the Restrictions Roadmap is a deliverable under the Strategy that calls for action toward a toxic-free environment and forms part of the European Green Deal. According to the EC, one of the actions foreseen by the Strategy is a revision of REACH and other relevant product legislation to ensure that consumer and professional products do not contain the most harmful substances. Until REACH is amended, the Strategy aims to “prioritise carcinogenic, mutagenic and reprotoxic substances (CMRs), endocrine disruptors, persistent, bioaccumulative and toxic (PBT[)] and very persistent and very bioaccumulative (vPvB) substances, immunotoxicants, neurotoxicants, substances toxic to specific organs and respiratory sensitisers for (group) restrictions” for all uses. To facilitate this action, the EC prepared the Restrictions Roadmap to prioritize these substances for (group) restrictions under REACH.

The Restrictions Roadmap provides detailed information to stakeholders on all ongoing work on future restrictions under EU chemical legislation. The Rolling List of substances will become the basis for future planning under REACH and is intended to allow companies and other stakeholders to be prepared better for potential upcoming restrictions. These restrictions will address a wider range of their uses — industrial, professional, and in consumer products. The EC will review the Restrictions Roadmap regularly and update it as necessary to maintain flexibility and its commitment to ensure progress toward protecting human health and the environment from the most harmful chemical substances. More information is available in The Acta Group’s April 29, 2022, memorandum.