Discursive strategies and paths forward for EU chemical legislation: bridging German stakeholder narratives on pollution and competitiveness for the announced REACH revision

The European Union’s (EU) chemicals policy attempts to balance human health and environmental protection with economic performance, innovation, and substance circulation. Responding to increasing pollution, assessment inadequacies, and economic hardships, the <i>von der Leyen II</i> Commission has announced a revision of the EU’s central chemical regulation, REACH (<i>Registration, Evaluation, Authorisation and Restriction of Chemicals</i>). We analyse stakeholders’ – NGOs, regulators, industrialists, researchers – interactions on policy implementation issues and future-oriented positions surrounding this revision. Given Germany’s pivotal role in EU’s chemical industries and politics, our <i>discursive agency analysis</i> investigates narratives of German stakeholders within broader EU chemical policy discourse. The dataset comprises explorative interviews, stakeholder workshop transcripts, and policy documents. We identify a discursive lock-in between two competing narratives: one prioritising chemical pollution reduction, the other boosting global competitiveness of German and EU chemical industries. This lock-in risks limiting the REACH revision to incremental changes, as stakeholders remain entrenched without resolving fundamental conflicts. To transcend stalemate, we explore underlying assumptions in both narratives that warrant scrutiny. A key opportunity lies in stakeholders’ expressed willingness to collaborate on developing and applying <i>New Approach Methodologies</i>. We propose forming a new discursive coalition that bridges market opportunities with substance grouping and chemical simplification strategies.