EU: Commission publishes Chemicals Industry Action Plan and Chemicals Simplification Omnibus

On 8 July 2025, the European Commission published a package of measures to strengthen the competitiveness of the European chemicals sector:

• European Chemicals Industry Action Plan;
• Chemicals Simplification Omnibus (“Omnibus VI”), which consists of two legislative proposals:
  • Proposal for a Regulation amending certain dates of application in the Classification, Labelling and Packaging of Substances and Mixtures (CLP) Regulation, and
  • Proposal for a Regulation amending certain requirements in the CLP Regulation, the Cosmetic Products Regulation, and the Fertilising Products Regulation;
  • Staff Working Document which explains the two legislative proposals in detail 
• Proposal for a Regulation to strengthen the governance of the European Chemicals Agency (ECHA).

(See Commission press release and Q&As.)

European Chemicals Industry Action Plan 

The Commission has identified high energy costs, unfair competition and weak demand as some of the key challenges the EU chemicals industry is having to grapple with. 

The European Chemicals Industry Action Plan focuses on four pillars: 

• strengthening resilience and global trade; 
• securing energy and supporting decarbonisation; 
• creating lead markets and boosting innovation; and 
• simplifying regulations.

With high energy costs being the main challenge for the EU chemicals industry, it’s not surprising that one of the key actions suggested in the Action Plan is the need for fast implementation of the existing Affordable Energy Action Plan (see our previous blog post). 

The Commission also envisages a number of other measures in the Action Plan, including (among others):

• creating of a Critical Chemicals Alliance to address the risks of production capacity closures in the sector and discuss key trade challenges (in Q4 2025);
• adopting of a new Bioeconomy Strategy (in Q4 2025);
• adopting a proposal for a new Circular Economy Act to unlock secondary materials markets and drive circularity in the chemicals industry (in 2026);
• deployment of chemical recycling under the Single-Use Plastic Directive with a public consultation (in Q3 2025) and adoption of an implementing act under the Single-use Plastics Directive concerning chemical recycling (in Q4 2025);
• assessing the feasibility to accounting emissions from non-permanent CCU products downstream as part of the ETS review (in Q2 / Q3 2026); 
• amending the “do no significant harm” (DNSH) criteria for pollution prevention and control under the Taxonomy Regulation (in Q3 2025);
• adopting a proposal for a targeted revision of the REACH Regulation (in Q4 2025); 
• proposing a PFAS restriction under REACH on the basis of ECHA’s opinion on the ‘universal’ PFAS restriction dossier (as soon as possible after ECHA concludes its assessment); 
• developing an EU-wide PFAS monitoring framework to centralise data as well as promote practical, science-based solutions for a sustainable shift by EU industry (in Q4 2026); 
• launching a dialogue on the challenges related to PFAS pollution (in Q2 2026); and 
• simplifying existing rules under the CLP, cosmetics and fertilisers regimes (under the Omnibus VI package – discussed below).

Omnibus VI legislative proposals 

The Commission is proposing to simplify the CLP Regulation, the Cosmetic Products Regulation and the Fertilising Products Regulation as follows:

• CLP regime – the changes seek to simplify labelling rules for hazardous chemicals, allowing more flexible, easy-to-read designs, expanding digital labelling, and easing advertising rules to reduce costs and complexity.
• Cosmetics regime – the changes seek to clarify procedures and introduce clear timelines for exemptions from substance bans, streamlining criteria. Guidance covers cosmetic products with constituents classified as CMRs—carcinogenic, mutagenic or reprotoxic substances—ensuring consumer safety. The Commission retains power to act on health risks after consulting the Scientific Committee on Consumer Safety.
• Fertilisers regime - the Commission proposes to remove extended registration requirements and applying standard REACH rules, easing market access, clearer criteria and methods for assessing micro-organisms in plant biostimulants, and simplifying processes.

The first legislative proposal aims to postpone the dates of application of the mandatory formatting requirements, provisions on advertisements and distance sales, obligations laying down six month deadlines for the label update and rules on the labelling of fuel pumps, in Regulation 2024/2865 which relates to the CLP Regulation. 

The second legislative proposal deals with the changes to the requirements in the CLP Regulation, Cosmetic Products Regulation and the Fertilising Products Regulation. 

Next steps 

The two draft Regulations in the Omnibus VI package and the draft Regulation to strengthen the governance of ECHA will now need to be negotiated and agreed on by the European Parliament and Council before they can become law. The draft Regulations are subject to the “ordinary legislative procedure”, which usually takes around 12-18 months. 

The Commission is also expected to adopt a separate proposal by the end of 2025 for targeted changes to the REACH Regulation to simplify those rules and speed up the procedures for industry. 

Further information 

For more information, see the following Linklaters materials: 

• Simplification of EU Chemicals Regulation – Defense Readiness Omnibus and Chemicals Industry Action Plan
• Omnibus Tracker.