The Federation of the European Sporting Goods Industry (FESI) welcomes the European Commission's initiative to revise the REACH Regulation, one of the most comprehensive pieces of chemical legislation globally. FESI and its members have long supported REACH's objectives: to ensure a high level of protection of human health and the environment, while maintaining the internal market and enhancing competitiveness and innovation.

Our members are at the forefront of voluntary chemical management best practices. Many companies already apply comprehensive Restricted Substances Lists (RSLs) and Manufacturing Restricted Substances Lists (MRSLs) such as those developed through the Apparel and Footwear International RSM Management (AFIRM) Group and Zero Discharge of Hazardous Chemicals (ZDHC) programme. These tools go beyond regulatory requirements and are part of industry-led efforts to phase out hazardous substances and ensure safe and sustainable product manufacturing across global value chains.

However, we are increasingly concerned that recent and upcoming initiatives under the European Green Deal and the Chemicals Strategy for Sustainability (CSS), including Green Claims Directive (GCD),the Eco-design for Sustainable Products Regulation (ESPR), and emerging concerns around "Substances of Concern” (SOCs), risk diluting the role of REACH. These frameworks, while often well-intentioned, have started to introduce de facto restrictions or compliance demands outside the REACH framework, potentially undermining REACH's legal certainty, transparency, and risk-based methodology.

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27 June 2025

Following the European Commission’s presentation of its REACH revision plans at the April CARACAL meeting, FESI has agreed to update its position paper to address key concerns raised by the industry. We are pleased to inform you that the final version of our updated position paper is now complete and will be shared with Commission officials working on the REACH revision on Monday morning.

This update is part of our continuous engagement to ensure the sporting goods sector is adequately represented in this crucial legislative process. The revised position reflects member feedback on our 2 versions.

Executive Summary – Key FESI Asks in the REACH Revision

1. Preserve REACH as the central chemical regulation framework
   Safeguard its global leadership role by preventing parallel regulatory systems that dilute legal clarity. (i.e: ESPR SoCs, Green Claims Hazardous Substances)
2. Maintain a risk-based approach
   Reject hazard-only mechanisms like automatic application of Generic Risk Approaches (GRA) or Mixture Assessment Factors (MAF) unless scientifically and exposure-justified.
3. Ensure simplification and proportionality
   Especially for SMEs and low-volume substances; avoid overly burdensome requirements that do not improve safety outcomes.
4. Protect innovation and circularity
   Allow for proportionate phase-ins of legacy substances in recycled materials to support sustainable practices.
5. Harmonise and digitalise
   Promote interoperable digital tools, harmonised test methods, and consistent enforcement across Member States to preserve the EU single market.
6. Avoid regulatory overlap
   Ensure coherence with related files such as the ESPR and Green Claims Directive and prevent backdoor substance restrictions.

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