The European Chemicals Industry Action Plan (CIAP) aims to strengthen the EU European Union (European Union ) chemical sector while prioritising safety, sustainability, and climate goals. The plan includes proposed actions such as forming a Critical Chemicals Alliance, simplifying labelling rules, and introducing an Advanced Materials Act by the end of 2026 to foster innovation in materials essential for clean technology and the circular economy. However, the lack of clear definitions for "advanced" materials and the challenges in properly assessing their safety and lifecycle risks are a concern. This highlights the need for reliable data and established test methods and risk assessment methodologies targeted at advanced materials that allow  navigating these complexities.

European Chemicals Industry Action Plan (CIAP)

The European Commission (EC) has put forth a plan called the Chemicals Industry Action Plan (CIAP), which aims to strengthen the chemical sector in the EU while also focusing on climate goals and zero pollution ambitions. One of the key points of this plan is to ensure that chemicals produced are safe and sustainable. For example, the plan suggests limiting the use of PFAS, except in cases where no safe alternatives are available. In addition, the long-awaited revision of REACH is due by the end of 2025. The governance, mandate and functioning of the European Chemicals Agency will also be reinforced through a proposal for a separate ECHA Basic Regulation.

Proposed actions

In the coming years, several concrete actions are planned. By late 2025, a Critical Chemicals Alliance will be formed to safeguard key value chains. The plan also aims to simplify rules around labelling and packaging, and to implement new surveillance mechanisms for imported goods (including those directly to consumers via webshops). By 2026, the plan foresees further legislative steps such as digital product passports, a roadmap for phasing out animal testing and the Advanced Materials Act.

Support for Advanced Materials?

The CIAP foresees the introduction of the Advanced Materials Act by the end of 2026. This new act will be designed to stimulate and reward innovation in the chemical sector. The CIAP emphasises that the chemical industry plays a vital role in important sectors like energy, defence, and information and communication technology, all of which often rely on advanced materials. The plan also highlights the importance of innovation and sustainability in achieving the transition toward a clean and circular economy.

Reflection by RIVM

CIAP sets up a framework aimed at encouraging innovation in advanced materials while prioritising safety and sustainability. The Commission plan to develop EU Innovation and Substitution Hubs provides opportunityies but underlying mechanisms, mandate and tasks are still largely unclear. Currently, the legal focus of the planned Advanced Materials Act and how and to what extent this act will support safe and sustainable innovations of advanced materials remains to be seen. Similarly, alignment with existing horizontal chemicals legislations (e.g. REACH and CLP) and the Innovation and Substitution Hubs are still largely unclear.

The proposal for an Advanced Materials Act, along with a strong emphasis on innovation, lead markets, a circular economy, and safety, shows that the EC is aware that these materials needs special attention in regulations. RIVM notes that for scientists, policymakers and industry, the CIAP presents both new opportunities and challenges. CIAP offers clearer regulations and support for innovation, but also requires more data, exposure assessments and safe-and sustainable-by-design solutions.

The Advanced Materials Act is expected to be ready by the end of 2026. Currently, it remains unclear whether advanced materials will be defined by how they perform or by their unique properties, which will influence how their safety assessment will be implemented in regulation. Lessons learned for nanomaterials have shown that early clarity on regulatory requirements in safety assessment are needed to provide industry confidence on how best to invest in safe and sustainable innovations.

To ensure the safe and sustainable development of advanced materials, it is crucial to have reliable data sources, established standards, and valid methods for assessing their life cycle and safety. CIAP mentions things like a “common data platform” and overarching simplification processes in regulation, but it remains to be seen how well these will address the complexities associated with advanced materials.