Safe and Sustainable Chemistry: What Manufacturers and Importers Must Do in 2026

Key data

Manufacturers, importers and industrial users of chemical substances in the EU face a regulatory transformation that is worth anticipating. The Recommendation (EU) 2026/510, adopted on 6 March 2026, calls for a review of the European framework for assessing chemical substances and materials under the principle of safe and sustainable by design (SSbD). It is not a rule for immediate compliance, but those who ignore it today will have less room for maneuver when binding legislation arrives.

The message from the European Commission is clear: the way chemical products' safety and sustainability are assessed will change. Companies that get ahead will be able to adapt formulations and processes with time. Those that wait for mandatory rules will face much tighter costs and timelines.

What does this regulation establish?

Recommendation 2026/510 proposes a review of the European framework for assessing chemical substances and materials by applying the SSbD (Safe and Sustainable by Design) principle. This principle requires that safety and sustainability be integrated from the product design phase, not as a subsequent compliance requirement.

The changes anticipated by this recommendation affect two dimensions:

• Safety assessment criteria: Companies will need to anticipate changes in the standards used to assess whether a substance or material is safe, incorporating more stringent toxicological criteria.
• Sustainability criteria: Assessment will not be limited to safety for human health, but will include the environmental impact of the product's life cycle.

Although the recommendation is not binding, the Commission explicitly presents it as the regulatory roadmap that the EU will follow in sustainable chemistry. In the medium term, it may lead to binding legislation requiring products to be redesigned to minimize toxicological and environmental risks.

Economic and operational impact

The economic impact of this recommendation is not measured today in fines or fees, but in cost of future adaptation. Companies that do not prepare now will face higher investments when binding rules arrive.

The main vectors of operational cost are:

• Product reformulation: Sectors such as construction, technology, agriculture and health will need to adapt formulations to comply with new SSbD criteria. This involves reviewing raw materials, suppliers and manufacturing processes.
• More stringent technical assessments: Safety and sustainability assessment criteria will be more rigorous. Companies will need greater internal or external technical capacity to document compliance.
• Differential impact on SMEs: SMEs with lower technical capacity are the most vulnerable. The recommendation explicitly identifies them as the group that must prepare well in advance to comply with more stringent assessments of their materials.
• Supply chain: Industrial users of chemical substances are also affected, not just manufacturers. This means that companies that do not produce chemicals but incorporate them in their processes must review the traceability and documentation of their suppliers.

Who does it affect?

Recommendation 2026/510 affects all companies that manufacture, import or use chemical substances and materials in the EU. The sectors with the highest exposure are:

• Construction: Construction materials, adhesives, sealants, paints and coatings with chemical components.
• Technology: Manufacturers of electronic components and devices that incorporate chemical substances in their production.
• Agriculture: Manufacturers and importers of plant protection products, fertilizers and other chemical-based agricultural inputs.
• Health: Manufacturers of medical devices, pharmaceuticals and diagnostic products that use materials subject to chemical assessment.
• Industrial users: Any company that uses chemical substances as input in its production processes, regardless of the final sector.
• SMEs: With special attention to those with lower technical capacity, which will have more difficulty adapting to more stringent assessments.

Practical example

A medium-sized construction company that manufactures adhesives for coatings uses several chemical substances in its formulation that currently comply with the current REACH regulation. With the arrival of SSbD criteria, this company will need to demonstrate not only that its substances are safe for human health, but that the product design minimizes toxicological and environmental risks throughout its entire life cycle.

This involves reviewing which substances it uses, evaluating whether more sustainable alternatives exist, documenting the analysis and possibly reformulating the product. If the company waits for the recommendation to become binding legislation before starting this process, the adaptation timeline will be much shorter and the costs of reformulation and certification will be higher.

An SME in the same sector, with a small technical team, faces the same process but without the resources of a large company. That is why the recommendation explicitly identifies them: the time to prepare is now, not when the rule becomes mandatory.

What should companies do now?

1. Identify exposure: Determine whether your company manufactures, imports or uses chemical substances or materials that could fall within the scope of the SSbD principle. If you operate in construction, technology, agriculture or health, the probability is high.
2. Audit formulations and processes: Review which chemical substances and materials are currently used and whether they comply or could comply with more stringent safety and sustainability criteria. Documenting the current state is the starting point.
3. Evaluate the supply chain: If you are an industrial user, request information from your suppliers about the traceability and SSbD assessment of the substances they supply to you. Responsibility does not end with the manufacturer.
4. Strengthen technical capacity: SMEs should assess whether they need to incorporate specialized external technical advice in chemical substance assessment and sustainability. Waiting for binding rules to seek that support increases costs and shortens timelines.
5. Monitor regulatory developments: This recommendation is the first step in a roadmap that may lead to binding legislation. Establishing a system to monitor European regulations on sustainable chemistry is essential to not fall behind.