REACH was designed to make products safer, not more expensive. Yet in early 2026, many European manufacturers are discovering that good intentions don’t always translate into predictable outcomes. Individually, these measures pursue legitimate goals, protecting human health on the one hand and defending European industry from unfair trade on the other. Together, however, they are sourcing threats and risk cost increases across the entire supply chain. For downstream manufacturers in electronics, automotive, aerospace, and industrial equipment, the result is a growing sense of regulatory and commercial whiplash.
So why are epoxy resins once again caught between a rock and a hard place, in this case, chemical regulation and rising trade barriers, and what does this mean for companies trying to remain compliant, competitive, and resilient in the European market?
Understanding REACH
REACH reaches far deeper into everyday products than many manufacturers realise, often capturing companies that do not consider themselves “chemical players”. The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), which entered into force on 1 June 2007, fundamentally shifted responsibility for chemical safety onto industry. Under REACH, companies have to identify, assess, and manage the risks associated with substances they manufacture, import, or use, and demonstrate to the European Chemicals Agency (ECHA) that these substances can be used safely. 
The regulation applies broadly to:
- all chemical substances, whether used in industrial processes or embedded in finished articles such as electrical appliances or clothing,
- manufacturers, importers, and downstream users,
- non-EU manufacturers, indirectly, through EU importers or appointed only representatives who assume REACH obligations on their behalf.
If risks associated with a substance cannot be adequately controlled, authorities may restrict its use, require prior authorisation, or ultimately ban it.
February 2026 REACH SVHC Update: What Changed?
In February 2026, ECHA added two new substances to the REACH Candidate List of Substances of Very High Concern (SVHC), increasing the total number of SVHCs from 251 to 253.
The newly listed substances are as follows:
- Bisphenol AF (BPAF) (CAS No. 1478-61-1) and its salts: Listed as toxic for reproduction (Category 1). BPAF is a fluorinated analogue of Bisphenol A and is used in certain high-performance epoxy resins and polymers,
- n-Hexane (CAS No. 110-54-3): Added due to specific target organ toxicity following repeated exposure, particularly neurotoxic effects.
(Notably, this marks the first SVHC identification based mainly on neurotoxicity via the Article 57(f) “equivalent level of concern” route beyond traditional CMR and PBT classifications)
Where These Substances Appear in Industry
Analysis by Z2Data indicates that approximately 110 electronic parts with full material disclosures contain one or more of the newly listed SVHCs. These parts are mostly concentrated in power line filters, power entry connectors, and switches.
In these applications, the substances do not perform electrical functions. Instead, they are embedded in non-electrical structural materials:
- BPAF appears in many epoxy-based molding compounds, encapsulants, adhesives, and protective coatings, where it contributes to mechanical strength, insulation, and resistance to heat, moisture, and other chemicals.
- n-Hexane is used as a process solvent in a myriad of products, but also in the manufacture and processing of epoxy resins, acting as a solvent, extraction agent, or purification aid rather than a structural component of the polymer. Its presence in finished products, however, if any, is typically limited to trace residual levels.
Beyond electronics, these substances are widely used across automotive, aerospace, industrial machinery, construction materials, and specialty chemicals, making cross-industry supply-chain visibility increasingly critical as SVHC requirements expand.
Anti-Dumping Duties on Epoxy Resins: A Separate Policy Track
In mid-2025, the European Commission imposed anti-dumping duties on epoxy resin imports from China, Taiwan, and Thailand. These duties, ranging from approximately 10.8% to 33% and effective from 28 July 2025, were introduced following findings that exporters were selling epoxy resins at unfairly low prices, causing material injury to the EU industry.
Cost Propagation and Downstream Supply Chain Pressure
While the anti-dumping duties and the February 2026 SVHC update are formally independent measures, their combined economic effect is felt most acutely downstream. Anti-dumping duties increase the cost of imported epoxy resins, while REACH-driven SVHC compliance raises production, reformulation, and administrative costs for domestic producers using substances such as BPAF or n-hexane. The result is a generalized upward pressure on epoxy resin prices across the EU market, regardless of origin.
For manufacturers that rely on these epoxy resins as critical raw materials, particularly in electronics, automotive, aerospace, industrial machinery, and energy infrastructure, these cost increases propagate rapidly through the supply chain. Unlike resin producers, downstream manufacturers often operate with tight margins, fixed contracts, and limited short-term substitution options, especially where epoxy performance is tightly linked to product safety or regulatory qualification. As a result, higher resin costs directly affect bill-of-materials pricing, competitiveness of EU-made finished goods, and long-term sourcing strategies.
So this feels somewhat counterintuitive: while trade defence measures aim to protect domestic industrial production of epoxy resins and their capacity at the upstream level, REACH seems to restrict production with a higher cost in the EU. Additionally, the economic burden is again disproportionately borne by the much larger population of downstream users. For these companies, the origin of cost inflation, whether regulatory or trade-related, is largely irrelevant; what matters is the reliability of supply, the predictability of pricing, and the long-term feasibility of sourcing compliant materials within the EU.
Strategic Sourcing Risks and Unintended Market Reconfiguration
From a supply-chain perspective, the simultaneous increase in the cost of both domestic epoxy resins (due to stricter regulatory requirements) and certain imported resins (due to anti-dumping duties) creates a powerful incentive for supplier diversification outside of the EU and East Asia. This is only logical, because when traditional supply channels converge toward higher cost structures, rational procurement behaviour increasingly favours exploring alternative trade partners that are not subject to the same combination of price penalties and regulatory cost internalization, which in practice, could favor alternative suppliers in other duty-free regions, including North America.
Hence, this shift does not imply regulatory non-compliance, but rather a geographic reconfiguration of sourcing within existing trade and chemical regulations. In practice, however, such „adjustments“ may reduce demand for EU-produced epoxy resins, even as those producers are formally protected from unfair competition. Over time, this creates a risk of partial decoupling between European resin production and European manufacturing demand, as downstream industries seek more cost-conscious sourcing options elsewhere.
From a policy standpoint, the EU is simultaneously pursuing regulatory leadership in chemical safety and strategic autonomy in industrial production, yet these goals do not always align seamlessly at the supply-chain level. While the EU appears willing to accept higher input costs as the price of improved health and environmental outcomes, the long-term implications for manufacturing competitiveness remain uncertain, particularly in globally traded, cost-sensitive sectors. For European citizens, this can mean safer everyday products and lower exposure to hazardous chemicals, but also the possibility of higher prices, pressure on manufacturing jobs, and reduced competitiveness in industries that impact the wider economy. The challenge for policymakers here lies in securing the public-health benefits of stricter chemical regulation without weakening industrial resilience and affordability across the EU.
Looking Ahead
At the same time, it is important to mention as well as emphasize the fact that REACH exists as its main purpose to protect EU citizens and the environment from harmful chemical substances, which is an unequivocal public good. Beyond restriction, the regulation is first and foremost intended to drive innovation, incentivizing R&D into safer, more sustainable alternatives to hazardous compounds.
There are precedents showing that this model can work: under REACH, substitution efforts have led to measurable improvements, such as the significant reduction of arsenic emissions in Murano glass production, while broader data indicate a substantial decline in the use of substances of very high concern across the EU market.
If successful, this approach allows European industry to compete on the basis of advanced materials and regulatory leadership rather than cost alone. At the same time, experience from other sectors, such as solar manufacturing, serves as a cautionary reminder that regulatory ambition alone does not guarantee the retention of domestic industrial capacity if cost structures and global competitiveness shift elsewhere. In that sense, REACH offers a pathway to maintain domestic manufacturing capacity while improving health and environmental outcomes, provided the transition is supported by timely innovation, industrial investment, and supply-chain adaptation.
