REACH Revision Uncertainty Grows as Comitology Route Gains Attention

Signals of a Shift to Annex Changes

In written answers ahead of the informal Environment Council meeting on 5 and 6 February 2026, Dutch ministers noted that the European Commission has not yet made any official statements about the future of the REACH revision. However, they acknowledged that such reports are circulating and that the issue is on the Netherlands’ radar.

For industry, the distinction matters. Annex changes via committee procedures can be a pragmatic route to make targeted technical updates, but they are not the same as reopening the REACH legal text through the usual legislative process. A narrower, annex-led path could shape timelines and stakeholder engagement, and it may limit how comprehensively the EU can address systemic issues such as procedure speed, predictability and the overall burden of compliance.

The Netherlands Still Backs a Full Revision

The Dutch position is that a full revision along the lines of the EU’s chemicals strategy remains the preferred route. At the same time, the government signalled that some ideas could be advanced without amending the core REACH text. It framed those measures as potentially reducing administrative burden while strengthening protection of people, animals and the environment compared with current practice.

The Netherlands also echoed parliamentary concerns about decision-making at the right political level. While committee-based decisions are part of the EU’s democratic framework, ministers agreed that major policy choices should, where possible, be handled transparently through the Council and the European Parliament.

What to Watch in 2026

For manufacturers, importers and downstream users, the immediate takeaway is uncertainty about the legislative route rather than a confirmed change in direction. Companies should continue to monitor EU timelines and be ready for two parallel tracks: a broader revision that could reshape key parts of REACH, and incremental annex or implementing changes that may arrive sooner and affect specific obligations.

Summary

The Netherlands is signalling continued support for a full REACH revision aligned with the EU chemicals strategy, even as it acknowledges rumours of a more limited, comitology-driven approach. The coming months will be important for understanding whether the Commission pursues a comprehensive proposal, targeted annex updates, or a combination of both.