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EU Commission Proposes the Simplification of EU Chemicals Rules for Defence Applications
Friday, June 20, 2025

On 17 June 2025, the European Commission issued a Defence Readiness Omnibus in the form of a Communication accompanied by several legislative proposals (see full list).

The Commission’s proposal aims to speed up defence investments and thereby increase the Member States’ and industry’s capabilities and infrastructures. It notably acknowledges the unfitness of the current regulatory environment of the EU in times of international tensions, including hindrance by environmental legislations.

The package encompasses a proposal accommodating certain requirements of the EU’s chemicals legislation to defence needs by way of amendments to REACH (Regulation (EU) 1907/2006), the CLP (Regulation (EU) 1272/2008 on classification, labelling and packaging) and the BPR (Regulation (EU) 528/2012 on biocidal products).

The proposal foresees the possibility for Member States to exempt certain substances from the requirements of the above cited Regulations “where necessary in the interests of defence”. While such a possibility already exists under all three Regulations, the proposal appears to provide further facilitation, by withdrawing the requirement that the exemption shall only be granted in “specific cases”. This aims to respond to the Member States’ particular caution so far in the use of the exemption.

It further amends the POPs Regulation (Regulation (EU) 2019/1021 on persistent organic pollutants) to ensure that defence readiness be considered in the preparatory stages of substances restriction and prohibition processes.

The package also includes a Commission Notice providing companies with guidance on the application of the sustainable finance framework, the Taxonomy Regulation, the Corporate Sustainability Reporting Directive (‘CSRD’) and the Corporate Sustainability Due Diligence Directive (‘CSDDD’) to the Defence industry.

This new package is issued in a context of intensified calls for simplification by Member States and certain political groups, to which the Commission has already responded via a series of proposals. A broader simplification initiative addressing the requirements of the CLP Regulation is notably expected to be issued on 2 July. Intel suggests that the initiative may be followed by the issuance of a second part later this year.

While this will generate further uncertainties for the industry in the next months, the Commission has shown a strong interest towards input from the industry. Involvement in ongoing discussions with stakeholders is thus key for any industry actor willing to weigh in in the process before the finalization of the proposals this year.

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