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REACH Reform: Don’t ignore new science on Chemical Mixtures

June 25, 2025 By Michael Warhurst

REACH Reform: Don’t ignore new science on Chemical Mixtures

The European Commission is currently finalising a revision of the EU’s main chemicals law, the REACH regulation. In the time since REACH was agreed, almost 20 years ago, there has been a big leap forward in our understanding of the toxic effects of the cocktails of chemicals we are all exposed to. We now know that REACH does not provide a high level of protection for human health and the environment from such mixtures.

This revision is a crucial opportunity to update REACH to improve protection from everyday mixtures of chemicals. Implementing a mixture assessment factor (MAF), an extra safety factor in chemical risk assessment, is an effective and pragmatic way to ensure protection from chemical mixtures.

Our new briefing How to address chemical mixture effects in the REACH revision provides details about how such a MAF would work.

Exposure to chemical mixtures is a reality of everyday life

People, wildlife and the wider environment are constantly exposed to a complex cocktail of known and suspected harmful chemicals through air, water, food, consumer products and other routes. The combined exposure to these chemical mixtures can trigger adverse impacts on our health and the environment, even when each chemical is present at low concentrations, below a level considered safe in single-substance assessment. This is called the ‘cocktail effect’ or ‘mixture effect’.

In March 2022, CHEM Trust published a report, “Chemical cocktails – The neglected threat of toxic mixtures and how to fix it”. This report also examined the science of chemical mixtures, and recommends key policies to address this threat, including a MAF.

Since then, important scientific publications, such as a study of neurotoxic chemical cocktails in blood from pregnant women, have continued to highlight the additivity of harmful effects of chemical mixtures and the fact that single-substance risk assessments, overlook risks to human health and the environment.

A mixture assessment factor is a pragmatic and protective solution

In 2020 the Commission produced a staff working document on chemical mixtures, which concluded that “The application of a mixture assessment factor seems to be the most pertinent for industrial chemicals under REACH, but it is applicable also to other regulatory areas, where the available data are insufficient to allow an assessment of actual co-exposure situations.”

Our new MAF policy briefing explains why a simple MAF is the most pragmatic approach to ensuring that risks from chemical mixtures are identified and can be managed. More complex approaches are possible, but they would require companies to develop burdensome, specific mixture assessments requiring a lot of data which are most often not available.

The inclusion of MAF in the REACH revision has been backed by a letter to Commission President von der Leyen signed by 250 European scientists.

Antonia Reihlen, Chemical Policy Expert at CHEM Trust says:

EU-funded research has demonstrated that mixtures matter: our exposure to cocktails of chemicals has negative impacts. Science has shown that we – and nature -will not be adequately protected without the additional safety factor of a Mixtures Assessment Factor. It is high time that the Commission listens to the science and updates REACH with a MAF.

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Tagged With: Chemicals, EU, EU Commission, MAF

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