The European Commission has proposed amendments to key EU chemicals legislation, including REACH, to broaden national defence exemptions and accelerate defence readiness by 2030. This legislative move, announced on 17 June 2025, directly impacts chemical manufacturers, defence suppliers, and stakeholders across industrial supply chains operating under EU regulations.
These changes will provide greater flexibility for Member States to exempt certain substances from regulatory obligations when used for defence purposes. This revision addresses long-standing concerns about the limited and inconsistent application of such exemptions, which currently delay the deployment of critical materials and technologies necessary for Europe’s strategic defence posture.
Broader Exemptions Across Multiple EU Chemicals Laws
The proposed regulation amends five pieces of legislation: REACH (Regulation (EC) No 1907/2006), CLP, Biocidal Products, Persistent Organic Pollutants, and the European Defence Fund Regulation.
Under REACH, Article 2(3) is revised to remove the restriction limiting defence exemptions to “specific cases.” This change allows national authorities to more easily approve exemptions for substances, mixtures, and articles essential to defence operations. Similar language updates are applied to the CLP and Biocidal Products Regulations to ensure consistency across the chemicals acquis.
Persistent Organic Pollutants (POPs) regulations will now require defence needs to be considered early in the EU’s international negotiations, allowing the bloc to propose exemptions before substances are listed under the Stockholm Convention.
Implications for Industry and Supply Chains
For manufacturers, particularly in chemicals, coatings, electronics, and materials processing, this marks a shift toward faster regulatory pathways when supplying the defence sector. The revised rules also acknowledge the sensitive nature of some chemical data—allowing exemptions from reporting obligations on national security grounds.
The proposal responds to concerns raised during public consultations about delays in defence production caused by environmental permitting and chemical restrictions. The Commission clarified that “defence readiness” now includes indirect impacts on supply chains, meaning more upstream stakeholders must assess potential regulatory changes in advance.
EDF Reforms Extend Testing and Funding Flexibility
The amendments also affect the European Defence Fund (EDF), allowing EDF-funded testing outside the EU—such as in Ukraine—and enabling co-financing Member States to access project results on fair terms. This aims to reduce administrative delays and incentivise greater collaboration across the defence R&D landscape.
Changes to EDF eligibility and award criteria take effect retroactively from 1 January 2025, giving immediate benefits to ongoing projects.
