From the “Green Wave” to the “Industry of Industries”: EU-level stakeholder debates over the announced REACH Revision and learnings from discourse analysis for EU policy-making

In the European Union (EU), the production, use, management and regulation of chemicals is structured around its main regulatory framework, REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). Almost 20 years after its enforcement, the von der Leyen II European Commission announced a revision of REACH for the first quarter of 2026. The Commission’s repeatedly postponed REACH reform is underpinned by challenges of governing chemicals amid widespread pollution, assessment inadequacies and wider geopolitical and economic pressures impacting the European chemical industries. With the announcement of reforming REACH, stakeholders have intensified negotiations about the design and implementation of future EU chemicals governance. Focusing on the ongoing debate surrounding the REACH revision, rather than its eventual legal outcome, the paper explores discursive dimensions of EU chemicals policy-making in real time. Using a discursive agency analysis, we empirically examine how different stakeholder groups – environmentalists, industrialists, animal welfare advocates, SMEs, trade unions, regulators, policymakers and academia – position themselves within the politics surrounding the REACH revision as well as on policy implementation issues. The analysis draws on a dataset comprising 36 in-depth semi-structured interviews, a transcript of a stakeholder workshop in Brussels and 62 policy documents from an open stakeholder consultation on the REACH revision in April 2025. We identify three narratives: one emphasising chemical pollution, one calling for increased competitiveness of EU chemical industries and one opposing animal testing. Moreover, a combination of two discursive strategies stands out, used by stakeholders across all narratives to make themselves visible within them. Seemingly rational, science-based patterns (scientification) are linked with the delegitimation of discursive opponents to advance actors’ own policy preferences – "my opponent acts in a non-scientific way". This analysis enables the identification of limitations and possibilities in current debates on policy-making in the REACH revision context. A broad majority of stakeholders converges on some aspects that could constitute pragmatic policy compromises, such as improved compliance of non-EU chemical imports or enhanced supply-chain communication through the digitisation of safety data sheets. However, we also highlight areas where trade-offs or compromises appear unlikely, given entrenched stakeholder positions, such as generic approaches to mixtures and risk assessment, the essential-use concept or earlier involvement of industry in regulatory processes. We suggest connecting aspects from industrialists and environmentalists to potentially overcome locked-in positions.