Discursive Strategies and Paths Forward for EU Chemical Legislation: Bridging German Stakeholder Narratives on Pollution and Competitiveness for the Announced REACH Revision

Abstract

Speaker: Henry Hempel The European Union’s (EU) chemicals policy seeks to balance human health and environmental protection with economic performance, innovation in substances and testing methods, and the free circulation of substances. In response to increasing chemical pollution, assessment inadequacies and economic hardships, the von der Leyen II Commission has announced a legislative proposal to revise the EU’s central chemical regulation, REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), scheduled for the last quarter of 2025. We analyse the interactions of stakeholders – NGOs, regulators, industry and researchers – concerning policy implementation issues and future-oriented positions related to this revision. Given Germany’s pivotal significance in the EU’s chemical industries and policymaking, alongside its broad range of involved actors, our discursive agency analysis investigates the narratives of German stakeholders within the broader EU chemical policy discourse. The dataset comprises explorative interviews, stakeholder workshop transcripts and policy documents. We identify a discursive lock-in between two competing narratives, one prioritising the reduction of chemical pollution, the other boosting the global competitiveness of German and EU chemical industries. This lock-in risks limiting the REACH revision to incremental changes, as stakeholders remain entrenched and fundamental conflicts unresolved. To break this impasse, we explore underlying assumptions in both narratives that warrant scrutiny. A key opportunity lies in stakeholders’ expressed willingness to collaborate on developing and applying New Approach Methodologies. We propose forming a new discursive coalition that bridges market opportunities with substance grouping and chemical simplification strategies.