Editor’s Note: This article was written before the current administration took office on Jan. 20.
For all the reasons you might imagine, 2025 is an especially challenging year to speculate on what to expect regarding global industrial, agricultural and biocidal chemical regulatory and policy initiatives. We give it our best shot below.
Global Chemical Policy
Given the European Parliamentary elections this past summer and the right-wing shift they brought about, along with the new Trump administration, change in chemical policy is expected on both sides of the Atlantic. The Trump administration and Republican congressional dominance portend significant policy changes, most pronounced in regulatory and policy initiatives reversing the Biden-Harris climate program and environmental justice (EJ) agenda.
How the administration’s focus on deregulation and “right-sizing” the federal bureaucracy may impact more nuanced chemical product law and regulation is unclear. Fears that the now-infamous “Project 2025” document is a Trump administration blueprint and not a set of detailed stakeholder suggestions will influence reactions to U.S. Environmental Protection Agency (EPA) decisions both internally and externally.
How the new world order is likely to evolve also is unclear. At the least, here in the United States the double whammy of Loper Bright, the blockbuster Supreme Court decision overturning the long-standing doctrine of “Chevron deference,” and a hardened resolve of the environmental non-governmental organization (eNGO) community to challenge judicial attempts to dismantle the Biden-Harris climate gains suggest a great deal of litigation is in our future.
Career staff at the EPA can be expected to be torn. While a Trump-appointed leadership team can be expected to remain faithful to Trump’s election promises to slow the transition to renewable energy, jump-start fossil fuel extractions, and undo EJ initiatives, career staff may be understandably less motivated, if not opposed, to these policy changes.
A revisitation of the Biden-Harris positions on The Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg) implementation, in particular core concepts including “reasonably foreseen,” “to the extent necessary,” “systematic review,” and “best available science,” is expected. What is less clear is whether change will come in the form of legislative amendment, regulatory and policy implementation or litigation. Probably all the above, suggesting 2025 will be extraordinarily busy and interesting.
Legislative Initiatives
The Republicans’ razor-thin margin in the U.S. House of Representatives and the equally divided U.S. Senate will be significant impediments to getting any meaningful legislation passed. Toxic Substances Control Act (TSCA) fees are up for reauthorization in 2026, and there is considerable interest within the chemical community to revisit Lautenberg.
Our own multi-year commitment to fixing the EPA’s deeply flawed new chemicals program, as seen in the extensive work of our two industry coalitions, Coalition for Chemical Innovations and TSCA New Chemicals Coalition, will continue in 2025 with renewed resolve and vigor. Similar policy shifts and uncertainties are expected under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Endangered Species Act (ESA) in the agricultural and biocidal area, but perhaps to less dramatic effect.
EU Developments
The European Union (EU) Parliament’s shift to the right also indicates change is afoot. How exactly this change will be expressed is unclear. 2025 marks the first year companies must report under the EU Corporate Sustainability Reporting Directive, an initiative that strengthens reporting on corporate social and environmental information.
The new Parliament may have shifted right, but the EU’s deeply rooted commitment to sustainability and circularity will continue to influence global corporate behavior. Layered on top of expected regional differences in chemical policies and regulations is the specter of import tariffs and their impact on investments and supply chain predictability, another source of considerable uncertainty.
PFAS
The EU’s proposed ban of per- and polyfluoroalkyl substances (PFAS) will continue to advance. The emphasis is laser-focused on prohibiting PFAS in consumer products. Expect to see essential use criteria emerge in 2025, a much-anticipated element that will generate significant interest. The new European Commissioner for Environment, Water Resilience and a Competitive Circular Economy, Jessika Roswell, Minister for European Union Affairs of Sweden, seems focused on balancing chemical safety with EU competitiveness, but time will tell how this balancing plays out in regulatory and policy initiatives in 2025.
Canada’s more measured approach to PFAS regulation is underway, with the PFAS survey of some 312 specific PFAS due Jan. 29, 2025. Canada’s Minister of the Environment plans many more PFAS activities in 2025.
With Brazil’s REACH law enacted in November 2024, manufacturers and importers of non-exempt chemical substances above one ton per year will now be required to register them. This is a major achievement for the Brazilian government and a game-changing and precedent-setting event for South America, indicating significant change to the year ahead.
One fact remains constant. Relentless monitoring, engagement and advocacy are essential. Entities that are publicly committed to sustainability, reversing climate change and a more equitable social ordering will need to maintain those commitments regardless of new political leadership.
