Across the chemicals sector, compliance calendars are becoming increasingly congested. With new harmonised classifications under the Classification, Labelling and Packaging (CLP) regulations, and new REACH restrictions such as the microplastics restriction all having the same compliance date for all actors in the supply chain companies are facing a perfect storm of regulatory pressure.

On paper, aligning deadlines might seem efficient everyone meets the same compliance date, ensuring a level playing field. In reality, however, when all actors in the supply chain have the same compliance date, the resulting workload, uncertainty, and timing pressures ripple through the entire supply chain, hitting downstream actors the hardest.

The Domino Effect Down the Supply Chain

The most significant challenge, lies in timing. Manufacturers often work on complex compliance changes right up until the legal deadline. While understandable, given the need to interpret new requirements and manage testing or reformulation, this approach leaves little to no time for those further down the chain to react.

Distributors, formulators, and end users rely on upstream suppliers for updated classifications, new raw material data, and revised documentation and labels. If that information only becomes available shortly before (or even on) the deadline, downstream actors face an impossible race to update their own systems, documents, labels, and regulatory submissions in time.

This cascading delay can lead to non-compliance, disruption in product availability, or the need to withdraw materials temporarily from the market. In industries with long formulation cycles or complex supply chains the impact is particularly acute.

Operational and Market Consequences

Deadlines can also have unintended commercial effects. If some suppliers meet compliance requirements later than others, it can distort competition and create uncertainty in the marketplace. Distributors may struggle to source compliant materials, while manufacturers risk losing customers who cannot wait for reformulated products.

In addition, inventory write-offs often rise as businesses are forced to replace packaging or dispose of non-compliant stock. The operational cost can be substantial.

Towards Smarter Implementation

There is growing recognition across industry that a more phased approach would deliver better compliance outcomes. Regulators could consider staggered deadlines along the supply chain, allowing sufficient time between manufacturer compliance and downstream implementation.

In short, when it comes to chemical legislation, simultaneous deadlines may simplify administration on paper, but in practice they compress the entire supply chain’s compliance window. For those lower down the chain, that can mean racing against the clock with limited information and that’s a race few can afford to lose.

About BASA:

BASA is the UK’s independent voice for the £1.7 billion adhesives and sealants sector in the UK and Ireland, representing members through advocacy, technical guidance, and networking. As the Adhesives and Sealants Association, we champion innovation, compliance, and sustainability while supporting business growth and strengthening industry standards.