Background Chemical pollution has emerged as a critical planetary challenge, yet global regulatory responses remain fragmented and insufficient. In this context, the European Union’s REACH regulation has been considered a potential global benchmark due to its ambitious provisions, including the principle of “no data, no market,” the reversal of the burden of proof onto manufacturers, and the classification and substitution of hazardous substances. This review assesses the extent to which REACH has diffused internationally and influenced domestic chemical regulatory frameworks. Main text The review systematically analysed 36 peer-reviewed studies comparing REACH with chemical policies in the United States, Canada, Australia, Japan, South Korea, and China. Findings indicate only partial diffusion. South Korea and China have incorporated some REACH-inspired provisions, notably the “no data, no market” rule and the reversal of the burden of proof, though both adapted these principles to domestic priorities and implementation capacities. Other jurisdictions, including the United States and Canada, retained the distinction between existing and new chemicals and maintained regulatory approaches that place greater responsibility on public authorities. Australia relies heavily on industry self-assessment, while Japan continues to prioritize risk assessments by government agencies. Across jurisdictions, approaches to the identification and control of hazardous chemicals also diverge: whereas the EU emphasizes hazard-based criteria and substitution, others combine hazard and exposure considerations and allow broader discretion in prioritization. Conclusion Nearly two decades after its adoption, REACH has not achieved the global regulatory influence once anticipated. Instead of convergence, national frameworks continue to diverge, reflecting differences in institutional capacity, political priorities, and regulatory philosophies. The EU regime remains distinctive in its precautionary orientation and comprehensive scope, but its global diffusion has been constrained by both practical and ideological barriers. Further comparative and empirical research is needed to assess how national systems function in practice and whether future international initiatives can foster greater harmonization in chemical governance.

The global diffusion of EU chemical regulation: a review

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2026年5月27日

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Emanuela Bozzini

摘要

Background

Chemical pollution has emerged as a critical planetary challenge, yet global regulatory responses remain fragmented and insufficient. In this context, the European Union’s REACH regulation has been considered a potential global benchmark due to its ambitious provisions, including the principle of “no data, no market,” the reversal of the burden of proof onto manufacturers, and the classification and substitution of hazardous substances. This review assesses the extent to which REACH has diffused internationally and influenced domestic chemical regulatory frameworks.

Main text

The review systematically analysed 36 peer-reviewed studies comparing REACH with chemical policies in the United States, Canada, Australia, Japan, South Korea, and China. Findings indicate only partial diffusion. South Korea and China have incorporated some REACH-inspired provisions, notably the “no data, no market” rule and the reversal of the burden of proof, though both adapted these principles to domestic priorities and implementation capacities. Other jurisdictions, including the United States and Canada, retained the distinction between existing and new chemicals and maintained regulatory approaches that place greater responsibility on public authorities. Australia relies heavily on industry self-assessment, while Japan continues to prioritize risk assessments by government agencies. Across jurisdictions, approaches to the identification and control of hazardous chemicals also diverge: whereas the EU emphasizes hazard-based criteria and substitution, others combine hazard and exposure considerations and allow broader discretion in prioritization.

Conclusion

Nearly two decades after its adoption, REACH has not achieved the global regulatory influence once anticipated. Instead of convergence, national frameworks continue to diverge, reflecting differences in institutional capacity, political priorities, and regulatory philosophies. The EU regime remains distinctive in its precautionary orientation and comprehensive scope, but its global diffusion has been constrained by both practical and ideological barriers. Further comparative and empirical research is needed to assess how national systems function in practice and whether future international initiatives can foster greater harmonization in chemical governance.