European Commission Faces Delays in Implementing Hazardous Chemical Restrictions Under 2022 Roadmap
Introduction
A progress review conducted by ClientEarth and the European Environmental Bureau indicates that the European Commission has failed to initiate regulatory processes for seven of the 22 hazardous chemical groups targeted in its 2022 restrictions roadmap, and has effectively halted progress on an additional seven groups. The roadmap, announced in April 2022, was intended to phase out broad categories of toxic substances under the EU''s REACH chemical regulation framework.
Main Body
The review, published in 2026, assesses the implementation status of the restrictions roadmap four years after its launch. According to the report, the Commission has not commenced regulation for seven chemical groups and has frozen advancement on seven others. Environmental groups allege that these delays, which they characterize as unlawful, have resulted in approximately 98,000 tonnes of additional pollution from six of the groups. The largest contributor to this figure is lead in ammunition and fishing tackle, which experienced a 23-month delay; the European Chemicals Agency estimates that roughly 44,000 tonnes of lead are released into the environment annually from these sources. Other delayed restrictions include lead in bullets (linked to chronic kidney disease), substances in childcare articles associated with cancer and genetic mutations, calcium cyanamide fertilizer (a carcinogen), and a bioaccumulative flame retardant used in automobiles. Under REACH, the Commission is obligated to draft an amendment to the restriction list within three months of receiving expert committee opinions. The report found that this deadline has never been met, with delays ranging from 13 to 47 months and averaging two years. Some restrictions have been successfully enacted, including those on PFAS in firefighting foam, lead in PVC plastics, and polycyclic aromatic hydrocarbons in clay pigeon shooting. The Commission has not responded to requests for comment. The report also notes that certain chemical groups have been removed from the roadmap after committees advised against restriction or because the Commission opted for alternative regulatory pathways. The latest annual update of the roadmap has postponed timelines for several other groups without providing explanations. Mirella Miettinen, a chemical regulation researcher at the University of Eastern Finland not involved in the report, described the lack of political will as extremely frustrating and characterized the Commission''s administrative negligence as longstanding.
Conclusion
The implementation of the European Commission''s restrictions roadmap remains substantially incomplete, with environmental organizations urging the Commission to accelerate regulatory action, comply with its legal obligations under REACH, and improve transparency and resource allocation.