EU REACH Restrictions Face Scrutiny Over CMRs in Childcare Products and Lead Ammunition

The European Commission is set to discuss new EU REACH restrictions covering carcinogenic, mutagenic and reproductive toxic (CMR) substances in childcare products and lead in ammunition and fishing tackle during the REACH Committee meeting on 29 April 2026. Environmental and health NGOs are urging Member States to support stricter controls while criticising delays in the wider EU chemical restrictions agenda. In a joint letter dated 24 April, organisations including the European Environmental Bureau (EEB), HEAL and CHEM Trust welcomed the Commission’s proposed restriction on CMRs in childcare products under Annex XVII of the REACH Regulation. The proposal follows recommendations from the European Chemicals Agency (ECHA) and aims to reduce children’s exposure to hazardous chemicals.

CMR restrictions in childcare products

The proposed REACH restriction would introduce a dynamic link to Annex VI of the CLP Regulation, automatically covering newly classified CMR substances without requiring additional legislative amendments. NGOs argue this would improve regulatory certainty and incentivise safer product innovation. The proposal also includes a default concentration limit of 0.001% weight by weight for CMRs in childcare products. According to the letter, this threshold is intended to prevent intentional use of such substances while minimising contamination during manufacturing and processing. Industry stakeholders across consumer goods, retail, plastics, coatings and supply chains may face tighter compliance obligations if adopted. Importers and distributors would also need to review product portfolios and supplier documentation to ensure conformity.

Concerns over transition periods

Despite supporting the proposal overall, the NGOs criticised the Commission’s suggested 36-month transition periods for implementation and for newly classified CMRs entering Annex VI. ECHA previously recommended avoiding transition periods, arguing that existing classification procedures already provide sufficient preparation time. The letter also notes that the EU Toy Safety Regulation does not include similar delays for banned substances. The organisations additionally called for stronger action on endocrine disruptors (EDCs), warning that current REACH Article 68.2 provisions do not adequately address these substances in childcare products.

Lead ammunition and fishing tackle restrictions

The REACH Committee is also expected to discuss and vote on restrictions for lead in ammunition and fishing tackle. The NGOs acknowledged that the original February 2025 proposal has already been weakened, with lead bullets removed and some restrictions on lead gunshot delayed. However, they argue the remaining measures would still deliver substantial public health and environmental benefits. The letter claims the proposal could help protect one million children vulnerable to lead exposure through game meat and reduce poisoning risks for 135 million birds exposed to lead gunshot ingestion.

‘Restrictions Roadblock’ report criticises EU delays

Alongside the policy discussions, ClientEarth and the EEB published a report titled Restrictions Roadblock, alleging major delays in implementing the EU Restrictions Roadmap. According to the report, 14 out of 22 planned restriction files have effectively stalled, with only six restrictions adopted since the roadmap’s launch. Delays between ECHA opinions and Commission draft decisions reportedly range from 13 to 47 months. The groups accused the Commission of weakening or delaying chemical controls despite legal obligations to protect human health and the environment. For manufacturers, downstream users and compliance teams, the debate highlights increasing regulatory pressure around hazardous substances and the likelihood of stricter chemical governance across EU supply chains.