Substitution

The process of identifying and implementing safer and more sustainable alternatives to hazardous chemicals, driven by regulatory restrictions, market demand, and corporate sustainability goals.

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Last updated

15 May 2026, 09:34

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Latest Substitution developments

Source-backed regulatory and guidance signals tracked by Foresight, with the newest developments first.

Germany: Government Sets Out Position on EU PFAS Restriction

In March 2026, the German government confirmed in a Bundestag reply that the planned EU PFAS restriction remains in ECHA’s technical assessment phase until the end of 2026 and that a further public consultation began in late March. This signals that binding PFAS restrictions are still several years away but that Germany will push for targeted derogations and transition periods for essential uses, so PFAS‑reliant sectors should plan for substitution while preparing to justify critical exemptions.

dserver.bundestag.deGermanyGermanyEuropean UnionEuropean Union

Defra Issues UK REACH Review Authorisations for ADCR Consortium Chromate Primers

Defra has issued four UK REACH review‑report authorisation decisions for members of the ADCR Consortium, allowing continued use and formulation of chromate‑based wash, bonding and other protective primers, as well as primer formulation, for aerospace and defence applications in Great Britain. The decisions extend access to critical hexavalent chromium primer systems under UK REACH while tightening exposure‑control and monitoring obligations at GB sites and setting time‑limited review periods for future reassessment.

gov.ukUnited KingdomUnited Kingdom

EU NGO Criticises Commission’s Plans for Circular Economy Act

In April 2026, the European Environmental Bureau warned that the European Commission’s planned Circular Economy Act risks focusing too narrowly on recycling and market harmonisation while neglecting waste prevention, reuse, repair and non-toxic material cycles. If the proposal is not strengthened before it is tabled after summer 2026, companies may face a less transformative and predictable circular-economy framework, with missed opportunities to align resource use, waste policy and forthcoming REACH and chemicals-strategy reforms.

environment.ec.europa.euEuropean UnionEuropean Union

Switzerland: Empa and Textile Partners Develop PFAS-Free Plasma Coatings for Outdoor Clothing

Switzerland has highlighted an Empa-led, Innosuisse-funded project with textile manufacturers to develop PFAS-free plasma coating technologies for outdoor clothing, using organosilicon compounds and Safe and Sustainable by Design principles. This research, award recognition, and related SSbD briefing signal an accelerating shift toward viable PFAS alternatives in textiles, with future implications for product design choices, supply chains, and forthcoming regulatory restrictions on PFAS.

news.admin.chSwitzerlandSwitzerland

Dutch Government Sets Conditions for Supporting EU Omnibus Package on Plant Protection Products

The Dutch government has outlined its conditions for supporting the EU Omnibus package on food and feed safety, backing a shift to a risk-based re-evaluation system for plant protection products while insisting that protection levels for people, animals and the environment are not weakened. This signals that Dutch negotiators will push for flexible but stringent EU rules, limited extensions of grace periods and a faster transition to low-risk pesticides and biocontrol, shaping how future approval and withdrawal practices could affect users of plant protection products.

zoek.officielebekendmakingen.nlNetherlandsNetherlands

ECHA Ends Consultation on Draft REACH Annex XIV Recommendation for 2-(dimethylamino)-2-[(4-methylphenyl)methyl]-1-[4-(morpholin-4-yl)phenyl]butan-1-one (CAS 119344-86-4)

ECHA has closed the public consultation on its draft 13th REACH Annex XIV recommendation to prioritise the photoinitiator 2-(dimethylamino)-2-[(4-methylphenyl)methyl]-1-[4-(morpholin-4-yl)phenyl]butan-1-one (CAS 119344-86-4) for inclusion in the Authorisation List. This moves the substance a step closer to future authorisation requirements for UV inks and coatings in the EU, so users should start assessing dependence on it and preparing substitution or authorisation strategies.

echa.europa.euEuropean UnionEuropean Union

ECHA Closes Consultation on TMAD Candidate for Substitution Under BPR

ECHA has closed the Biocidal Products Regulation consultation on TMAD (formaldehyde released from glyoxal–urea reaction products) as a potential candidate for substitution and archived it on the previous consultations list following a 09 March to 08 May 2026 information period. This signals that assessment of TMAD for BPR product types 06, 11 and 13 is advancing and that future EU authorisation decisions may require substitution or tightly defined derogations for detergents, paints, adhesives, cooling systems and metalworking fluids using this active substance.

echa.europa.euEuropean UnionEuropean Union

Illinois House Schedules SoyFoam Firefighting Foam Resolution After Committee Approval

On 7 May 2026, an Illinois House committee unanimously recommended adoption of a non-binding resolution urging the State Fire Marshal and local fire departments to replace existing firefighting foams with soy-based SoyFoam, and the measure was placed on the House calendar. While not yet legally binding, this progress signals growing political pressure to phase out PFAS-based foams in Illinois, so EHS, procurement, and chemicals teams should monitor for follow-on legislation or procurement rules that could formalise a PFAS-free transition.

ilga.govUnited StatesUnited States

European Commission REACH Team Introduces HEFESTOS Study on Substituting Brominated Flame Retardants

The European Commission REACH Team has announced the HEFESTOS study, an EU-funded pilot project to develop practical substitution pathways for brominated flame retardants in construction, automotive, cables and other applications. This initiative signals strengthened EU focus on BFR substitution and stakeholder engagement, providing input that could shape future restrictions, guidance and support mechanisms for managing BFR risks.

circabc.europa.euEuropean UnionEuropean Union

American Sustainable Business Network Seeks Support for Bipartisan Legislation to Authorize EPA’s Safer Choice Program

In April 2026, the American Sustainable Business Network launched a broad sign-on letter urging US lawmakers to introduce and pass bipartisan legislation formally authorizing and funding EPA’s Safer Choice Program. If Congress takes up this proposal, statutory backing for Safer Choice could significantly strengthen US demand for safer-chemistry formulations, affect procurement standards across sectors, and increase pressure on manufacturers to invest in ingredient substitution and product reformulation.

docs.google.comUnited StatesUnited States

EU (ECHA) Starts BPR Approval Assessment of Arnica Montana Extract BAS 2403 as Candidate for Substitution

European regulators have accepted an initial Biocidal Products Regulation Annex I approval application for a specific Arnica montana extract (BAS 2403), with Switzerland leading the evaluation and the substance flagged as a candidate for substitution. For biocidal product manufacturers and formulators, this signals an upcoming EU decision that will define approval conditions and may drive substitution or reformulation of products using this extract once the BPC opinion and legal act are finalised.

echa.europa.euEuropean UnionEuropean Union

Investor Initiative on Hazardous Chemicals Sets Four Key Demands for Global Chemical Companies

An investor coalition coordinated by ChemSec and representing over $23 trillion in assets is intensifying engagement with major chemical producers, demanding greater transparency on hazardous-chemical revenues, time-bound phase-out plans for persistent chemicals, smaller hazardous portfolios, and 2030 targets to grow safer solutions. This raises strategic pressure on boards to align product portfolios with REACH, CSRD and tightening PFAS regulation, reduce long-tail litigation and remediation risks, and demonstrate credible transition plans to investors and customers.

chemsec.orgGlobalGlobalUnited StatesUnited StatesEuropean UnionEuropean Union

Change Chemistry and UMass Lowell Publish Policy Framework to Incentivise Sustainable Chemistry

In April 2026, industry network Change Chemistry and the University of Massachusetts Lowell published a joint policy framework outlining how targeted incentives could accelerate sustainable chemistry innovation, manufacturing, and market adoption. The report signals the types of grant, tax, procurement, and regulatory incentive packages that governments in the US, EU, and beyond may deploy, reshaping the economics of investing in safer, low-impact chemistries versus legacy substances and guiding future policy design.

assets-002.noviams.comUnited StatesUnited StatesEuropean UnionEuropean Union

EU Council: Sweden Sets Out Position on Omnibus X Pesticides Reforms (Cluster B)

In March 2026 Sweden submitted detailed comments to the Council on the EU’s Omnibus X food and feed safety package (Cluster B), advocating a more cautious approach to drone spraying, biocontrol definitions, grace periods, and data rules in the pesticides and MRL framework. If Sweden’s positions are reflected in the final legislation, the Omnibus reforms would lean toward stricter controls on hazardous and imported pesticides, narrower eligibility for simplified treatment of biocontrol products, and fewer loopholes in active-substance approvals and plant protection product authorisations.

data.consilium.europa.euEuropean UnionEuropean Union

ECHA Assessment of Regulatory Needs Recommends REACH Restriction and Authorisation for tris(mixed dodecyl and octyl)benzene-1,2,4-tricarboxylate

In April 2026, ECHA updated its Assessment of Regulatory Needs to flag 1,2,4-benzenetricarboxylic acid, mixed lauryl and octyl triesters (a high-tonnage trimellitate plasticiser) for a future combination of REACH restriction and authorisation. This non-binding assessment is a strong early warning for polymer and article supply chains to map uses, explore alternatives, and closely track forthcoming CLH, Candidate List, and restriction proposals affecting trimellitate plasticisers in the EU.

echa.europa.euEuropean UnionEuropean Union

ECHA Identifies Need for REACH Restriction on 4,4'-Methylenediphenol (BPF)

ECHA’s bisphenols group Assessment of Regulatory Needs concludes that 4,4'-methylenediphenol (bisphenol F, BPF; EC 210-658-2; CAS 620-92-8) warrants EU-wide restriction under REACH, with the ARN list entry for BPF shown as under development and last updated on 2 August 2024. This positions BPF and its derivatives among a small set of priority bisphenols likely to face group-based restrictions, so manufacturers and downstream users should plan for substitution, review polymer and resin portfolios for BPF content, and closely track the forthcoming German-led REACH restriction proposal.

echa.europa.euEuropean UnionEuropean Union

EU PAFF Committee Publishes Agenda For 5–6 May 2026 Phytopharmaceuticals-Legislation Meeting

The European Commission has published the agenda for the PAFF Committee’s Phytopharmaceuticals-Legislation meeting on 5–6 May 2026, which will consider multiple draft regulations on active substance approvals, non-renewals, extensions, and horizontal changes to EU plant protection product data and evaluation rules. These committee discussions and possible opinions are a major decision point that will shape upcoming EU measures on which plant protection products remain authorised, how quickly approvals are renewed or withdrawn, and what data companies must generate and submit for future PPP applications.

food.ec.europa.euEuropean UnionEuropean Union

EU PFAS Restriction Proposal: Viewpoint Challenges Unlimited Manufacturing Derogation

An April 2026 Viewpoint in Environmental Science & Technology argues that the preferred RO3b option in the EU’s proposed universal PFAS restriction—allowing unlimited PFAS manufacturing under relative emission factors—undermines the measure’s core goal of minimising emissions because PFAS are extremely persistent and no safe contamination level exists. It signals mounting scientific pressure for policymakers to adopt stricter approaches such as hard volume caps or time-limited derogations with fixed emission limits, implying that PFAS manufacturers and downstream users should prepare for tighter REACH controls than those currently favoured in the restriction dossier.

pubs.acs.orgEuropean UnionEuropean UnionEuropean Economic AreaEuropean Economic Area

EU/ECHA Marks Peracetic Acid “Under Assessment” for Candidate-for-Substitution Status in PT 2

On 17 April 2026, ECHA updated the peracetic acid (PT 2) biocidal active substance factsheet so that its “candidate for substitution” field now shows “under assessment” under the EU Biocidal Products Regulation. This default status does not yet mean the substance will be designated a candidate for substitution, but it signals renewed regulatory scrutiny ahead of the 2027 approval expiry that product authorisation holders using peracetic acid disinfectants should monitor closely.

echa.europa.euEuropean UnionEuropean Union

Netherlands Parliament Publishes Scientific Assessment of EU Food and Feed Safety Omnibus Proposal

In April 2026, Dutch Parliament’s EU science assessment concluded that the EU Food and Feed Safety Omnibus proposal (COM(2025)1030) would not simplify approvals and risks weakening pesticide and PFAS controls by removing periodic re-evaluations and shifting the burden of proof away from producers. These findings give Member States a strong evidence base to resist deregulation in the Omnibus package, increasing pressure to preserve precautionary standards, regular substance reviews, and more targeted fast tracks for safer biocontrol products.

tweedekamer.nlEuropean UnionEuropean UnionNetherlandsNetherlands

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How to read Substitution regulatory activity

Definition

What is Substitution?

The process of identifying and implementing safer and more sustainable alternatives to hazardous chemicals, driven by regulatory restrictions, market demand, and corporate sustainability goals.

Industry relevance

Why it matters

Substitution developments can change product scope, supplier expectations, market access, reporting duties, and risk ownership. Foresight tracks the signals early so teams can respond before obligations become urgent.

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Foresight monitors official sources, extracts structured regulatory intelligence, and maps alerts to a customer's products, substances, markets, and priorities so teams see the relevant signal with source evidence for review.

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