New rules for substances, plants and raw materials
New entries on the Candidate List, new hazard classes, the revised Industrial Emissions Directive and duties for raw material supply chains reach product stewardship, plants and procurement at the same time. COBACK reads the new publications every day and shows which of them could affect your substances, sites and supply chains, and why.
Topics and rules
What is changing, who in the company works with it and which legal acts are behind it.
Registration and substances of very high concern
REACH requires registration of every substance a company manufactures in or imports into the EU in quantities of one tonne or more a year. ECHA adds to the Candidate List of substances of very high concern regularly. Listed substances bring information duties along the supply chain. Product stewardship, regulatory affairs and sales are affected.
Examples
- REACH Regulation (EC) No 1907/2006
- German Chemicals Act (ChemG)
Classification and labelling
The new hazard classes for endocrine disruptors and for persistent substances (PBT, vPvB, PMT, vPvM) have applied to substances newly placed on the market since 1 May 2025 and to mixtures newly placed on the market since 1 May 2026. Substances already on the market before then must be classified and labelled accordingly by 1 November 2026, and mixtures by 1 May 2028. The CLP revision's rules on label format, advertising and distance selling were postponed to 1 January 2028. Product stewardship, labelling and online sales are affected.
Examples
- CLP Regulation (EC) No 1272/2008
- Delegated Regulation (EU) 2023/707 on the new hazard classes
- CLP amending Regulation (EU) 2024/2865
- Regulation (EU) 2025/2439 postponing the labelling rules
PFAS and restrictions
Restrictions under Annex XVII to REACH take effect with transition periods. The PFHxA restriction applies from 10 October 2026 to consumer clothing and footwear, paper and board food contact materials, consumer mixtures and cosmetics, among others. The universal PFAS restriction, by contrast, is still a proposal: ECHA's committees are assessing it, and the Commission and the Member States decide after that. Product development, product stewardship and sales to downstream users are affected.
Examples
- Annex XVII to REACH
- PFHxA restriction, Regulation (EU) 2024/2462
Plants, emissions and major accidents
The revised Industrial Emissions Directive requires, among other things, environmental management systems and emission limits as low as the best available techniques allow. In Germany the Bundestag passed the transposition act on 9 July 2026. It amends the Federal Immission Control Act and the Water Management Act, among others. Establishments with larger quantities of dangerous substances are also covered by the Major Accidents Ordinance. Plant management, environmental protection and process safety are affected.
Examples
- Industrial Emissions Directive (EU) 2024/1785
- German Federal Immission Control Act (BImSchG)
- Seveso III Directive 2012/18/EU
- German Major Accidents Ordinance (12. BImSchV)
Emissions trading and carbon border adjustment
Many chemical and basic materials plants fall under the EU Emissions Trading System, implemented in Germany by the Greenhouse Gas Emissions Trading Act. The definitive phase of the carbon border adjustment mechanism has run since 1 January 2026 and covers fertilisers, hydrogen, steel and aluminium, among other goods. Energy and climate management, procurement and customs are affected.
Examples
- EU ETS Directive 2003/87/EC
- German Greenhouse Gas Emissions Trading Act (TEHG)
- CBAM Regulation (EU) 2023/956
Raw materials and supply chains
The Critical Raw Materials Act requires large manufacturers of strategic technologies such as batteries to assess the risks in their supply chains for strategic raw materials at least every three years. Importers of tin, tantalum, tungsten and gold above set volumes have had due diligence duties under the Conflict Minerals Regulation since 2021. Procurement, sustainability and risk management are affected.
Examples
- Critical Raw Materials Act (EU) 2024/1252
- Conflict Minerals Regulation (EU) 2017/821
- German Mineral Raw Materials Due Diligence Act (MinRohSorgG)
Chemicals law outside the EU
Supplying the US, the UK or China means separate notifications or registrations there. In the US the Environmental Protection Agency has postponed the start of PFAS reporting under TSCA several times. In China, Order No. 12 of the Ministry of Ecology and Environment governs the registration of new substances. Regulatory affairs and export sales are affected.
Examples
- Toxic Substances Control Act (TSCA)
- UK REACH
- MEE Order No. 12 on new chemical substances (China)
The path of a change
Example: new substances on the Candidate List
01Law database
ECHA adds new substances to the Candidate List. COBACK reads the announcement together with the day's other publications.
02Relevance
The check against the digital twin gives a relevance score of 91. The reasoning names the ECHA source and one of the substances. According to the product documentation, your company uses this substance in two mixtures at its North plant.
03Open questions
What is open is whether the substance exceeds 0.1 percent by weight in the mixtures. COBACK asks that question and the laboratory confirms the value. The head of product stewardship then marks the change as relevant.
04Task
This creates tasks with steps, owners and deadlines: product stewardship updates the safety data sheets by 13 November 2026, sales informs the customers concerned and procurement asks the upstream suppliers about the substance.
Working with COBACK
Sources for substance and plant law
Every day COBACK reads new publications, for example from ECHA, EUR-Lex and China's Ministry of Ecology and Environment, along with official journals, parliaments and specialist media. Everything new ends up in one place.
Linked to your substances and sites
Each relevance score from 0 to 100 comes with its reasoning, the source and the products and plants from your twin it relies on. Where a fact is missing, such as a quantity or a concentration, COBACK asks.
Decision and tasks
A person on your side decides whether a change is relevant. It then becomes tasks with steps, owners and deadlines for product stewardship, plant management or procurement.
Groups with many companies
The twin knows your group companies and sites, including from public registers such as GLEIF. An assessment therefore shows which company or plant could be affected.
Frequently asked questions
Does COBACK replace our substance database or our safety data sheet system?
No. COBACK shows which new rules could affect your substances, sites and processes and, once you have decided, turns them into tasks. COBACK does not write safety data sheets.
How does COBACK handle proposals that have not been adopted yet?
COBACK also reads proposals and opinions, for example on the universal PFAS restriction, and assesses them like any other publication. Whether you prepare for them now is decided by a person in your company.
Does COBACK cover chemicals law outside the EU?
Yes. COBACK reads new publications from the EU and European countries, the Americas and Asia, and from international bodies, for example from China's Ministry of Ecology and Environment and the US Federal Register.
Does COBACK give legal advice?
No. COBACK assesses the relevance and explains it with sources. The decision is made by a person in your company.
