A Policy Shift That Puts Chemical Users First

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A Policy Shift That Puts Chemical Users First

Europe’s mechanical and plant engineering sector stands at the forefront of sustainable solutions — from energy-efficient production systems to cutting-edge climate technologies. Yet these highly complex machines and plants rely on thousands of individual components, many sourced through global supply chains that are deeply intertwined with the European chemicals sector. Against this backdrop, the European Commission’s Chemicals Action Plan is an important policy lever that can either strengthen or undermine Europe’s position as a competitive industrial hub.

Photo Credit: Nathan Rimoux on Unsplash

Dr. Sarah Brückner, Head of the Environment and Sustainability Department at VDMA, cautions that the Action Plan must strike the right balance between environmental ambition and practical feasibility for industry.
“On average, machine and plant manufacturers have more than a thousand individual parts in complex products — often with long and international supply chains. The Chemicals Action Plan must take these realities into account. Without early and differentiated consideration of the perspectives of the user industries, there is a risk of barriers to innovation, a decline in investment and a dangerous loss of competitiveness,” says Dr. Brückner.

Europe’s machinery builders — many of whom are medium-sized companies with deep roots in the region — are under growing pressure to deliver solutions for climate neutrality, resource efficiency, and circularity. But if chemical restrictions are poorly coordinated with industrial needs, they can disrupt supply chains, hinder product innovation, and delay the market introduction of more sustainable machines.

One key point the VDMA is advocating for is the inclusion of a binding Risk Management Option Analysis (RMOA) — a tool that ensures careful, evidence-based decisions about restricting substances.

“We therefore call for the Chemicals Action Plan to include a binding Risk Management Option Analysis (RMOA) as a standard instrument. Before substances are regulated, all options must be systematically examined and the impact on entire value chains taken into account. This creates transparency, reliability and protects Europe as an industrial location,” Dr. Brückner explains.

The ongoing debate over the proposed PFAS restrictions under REACH is a striking example of how complex and far-reaching chemical regulation can become when policy and practical implementation drift apart. PFAS — a broad group of substances used in everything from semiconductors to medical devices — play a crucial role in ensuring high performance and durability in many industrial applications. For machine and plant manufacturers, a sweeping ban without viable alternatives could create significant bottlenecks in production and delay critical technological advancements.

The PFAS restriction procedure under REACH in particular shows how difficult implementation becomes when regulatory concepts are not aligned with practice. Decision-making processes lasting several years, a lack of substitutes, unclear transitional periods and non-transparent communication on more than ten thousand substances make it clear that legislators must not bypass the reality of everyday industrial planning,” Dr. Brückner warns.

The VDMA also stresses that a fragmented approach — with overlapping definitions, inconsistent criteria, and chemical rules embedded across various pieces of legislation — only adds confusion and legal uncertainty for companies navigating these complex frameworks.
“The regulation of chemicals belongs in chemicals legislation — not in parallel legislation. In the same way, definitions for substance groups such as ‘most harmful substances’ or ‘substances of concern’ must not be incorporated into different laws without clear criteria and coordinated assessments,” she says.

For Europe’s machinery and plant engineering sector, what’s needed now is a Chemicals Action Plan that upholds high environmental and health standards while maintaining a clear, predictable, and practicable regulatory environment. This will enable Europe’s manufacturers to continue developing world-leading technologies — from climate-neutral production systems to efficient resource management solutions — and bring them to global markets without unnecessary hurdles.

The VDMA calls on policymakers to work closely with user industries, apply robust impact assessments, and ensure that any regulatory path forward is realistic, science-based, and fully aligned with the day-to-day complexities of industrial design and supply chains. Only then can Europe remain both a global leader in sustainability and a strong, innovative industrial powerhouse.

https://www.vdma.eu/

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