Behind the EU’s regulatory simplification: clean but not green?

“Less is more” is a common expression reminding us that the most impactful and satisfying results are sometimes achieved by focusing on simplicity over complexity and abundance. It encourages us to focus on what truly matters. 

At ZWE, we believe that a clean, circular approach is what truly matters when it comes to achieving long-term economic and environmental security in Europe. We also do not doubt that the European industry (including the chemical industry) plays an essential role in this transformation, and we fully support better harmonisation and smarter implementation of the existing regulatory framework.

‘’There’s a but in here…’’, we hear you thinking.

Indeed, there is.

We would like to see a “clean, circular economy” that not only ensures more durable and high-quality “Made in Europe” products and secondary materials but also fewer hazardous chemicals, less waste, and less pollution in our daily lives. However, achieving this under the mantra of “simplification,” as per the Commission’s recent legislative proposals, will be quite the challenge. 

“Clean” chemicals – too good to be true? 

Over the past months, the Commission has been on a simplification mission: ‘clean’ (chemicals and industry) now means ‘decarbonised’; ‘pollution’ equals ‘greenhouse gas emissions’. 

On 8 July 2025, the Commission released the so-called Chemicals package: a bundle of measures supporting the EU chemical industry. This is great from the point of view of a long-overdue legislative proposal to strengthen the European Chemicals Agency (ECHA) mandate. It is also somewhat worrying if we consider that other “simplification” rules do not promote harmonised, swift, and evidence-based actions, but rather lower the bar on chemical safety. Surprisingly, these same rules are promoted as something that “will maintain the highest level of protection of human health and the environment“.

Here’s a quick example: the Sixth Omnibus Regulation includes proposals to allow toxic chemicals (including those known to cause cancer) in some everyday consumer products, such as cosmetics and personal care items. 

Our immediate questions upon reading this:

• How does this maintain the highest level of protection of human health and citizens instead of undermining it?
• What happened to “phasing out the most harmful chemicals for non-essential societal use, in particular in consumer products”, promised in the Chemicals Strategy for Sustainability less than 5 years ago?

Take the ‘simplification’ of rules on labelling and packaging of products as a second example. In practice, this means that the revised rules securing better access to information (only adopted in 2024!), will be abandoned to the benefit of less “regulatory burdens” for industry and businesses.

But what’s the deal for consumers and other users? 

Well, they will be “encouraged to read the label and product information before use” (with no guarantee that the information about all hazardous chemicals and mixtures will be there in the first place). And they had better have a magnifying glass to read all these tiny letters, as companies will be allowed to use smaller fonts for key health and environmental warnings.

All this “simplification” is happening through opaque procedures and emergency-style tactics. Nowadays, addressing toxicity, emissions, pollution, and related risks (and even complying with existing rules) has been deemed too much of a “burden” for a chemical industry in crisis.

But let’s be clear: this only means that, ultimately, other circular economy actors will pay the price, including downstream businesses, end users, and recyclers – i.e. whoever wants to claim use of clean and safe materials. And the most significant burden and costs will be borne by all of us through public health –  in fact, this is already happening. Over the last few decades, and despite all the EU laws and regulations of the past 20 years, our economies (focusing on growth, Gross Domestic Product, and ever-increasing consumption) have been set up to prioritise efficiency, productivity, and convenience. The other side of this coin is that consumers’ health has been compromised, with an incredible number of products containing chemicals which have been linked to, among others, infertility and cancer. 

With all of this, we’ve failed to protect ourselves – including unborn children – from dozens of harmful chemicals, such as PFAS and bisphenols.

Will we be heading towards a truly clean circular economy?

On 1 August 2025, the Commission launched a consultation on the upcoming and highly anticipated) Circular Economy Act, to unlock markets for secondary materials and drive circularity. We certainly hope this call for evidence will recognise that “introducing standardised product labelling, product information, including toxic substances, and other transparency measures and tools focusing on circularity” is non-negotiable. 

If the Clean Industrial Deal’s ambition is to make the EU the world leader in the circular economy by 2030, it needs to accept that more sustainable products start with better chemical decisions. Increasing overall transparency and chemical traceability is simply a must. 

For a clean circular economy to function and succeed, safely using chemicals cannot be seen as a burden, but as the path to long-term competitiveness. The EU economy’s competitive edges should be high standards for safety and health; user/consumer trust in materials and products made and recycled in Europe; and high quality.

A ‘clean’ Circular Economy Act

The proven impact of chemicals on our health and on future generations shows that we cannot simply keep polluting and clean up ‘later’.

In a safe circular economy, the materials in use must be fit for purpose in both primary and secondary uses. This means they must be free from harmful chemicals from the outset. The EU Chemicals Strategy for Sustainability has promised as much, so the Circular Economy Act should follow the endorsed chemical strategy and promote adequate actions.

Ironically, the choice is simple: Europe can grab this unique opportunity and use simplification and circularity to improve the current situation and prevent future public health crises… or we can collectively remain sceptical about “clean chemicals”.