Executive Summary
In 2026, the chemical procurement landscape is reshaped by tightening EU regulations and global supply‑chain volatility. CSRD now demands granular Scope 3 disclosures, while CBAM and EUDR impose carbon and biodiversity costs on raw materials. The REACH revision of SVHC lists and new PFAS restrictions compel suppliers to prove low‑risk alternatives. The ongoing Hormuz crisis continues to pressure logistics, prompting a shift toward regional sourcing and digital traceability.
Regulatory Milestones for H1 2026
Corporate Sustainability Reporting Directive (CSRD)
The CSRD requires companies to integrate Scope 3 emissions into annual sustainability reports. For chemical buyers, this means:
Mapping indirect emissions across the entire material supply chain.
Verifying supplier carbon footprints through third‑party audits.
Aligning procurement policies with net‑zero targets.
Carbon Border Adjustment Mechanism (CBAM)
CBAM applies a carbon price to imported chemicals. Buyers must now:
Calculate embodied carbon in raw materials.
Negotiate CBAM certifications with suppliers.
Adjust contract terms to reflect carbon costs.
EU Deforestation Regulation (EUDR)
EUDR expands deforestation liability to chemical feedstocks. Procurement teams should:
Confirm zero‑deforestation certifications.
Track land‑use changes in supplier regions.
Integrate deforestation risk scores into supplier selection.
REACH SVHC List Updates
New SVHC substances identified in 2026 increase compliance risk. Suppliers must provide:
Material Safety Data Sheets (MSDS) with updated hazard ratings.
Alternatives dossiers for high‑risk substances.
Proof of substitution within the 12‑month compliance window.
PFAS Regulation
The EU’s PFAS ban on certain consumer products extends to industrial chemicals. Key actions:
Screen all downstream products for PFAS residues.
Replace PFAS‑containing intermediates with safer analogues.
Maintain traceability of PFAS usage in the supply chain.
Scope 3 Emissions: Accounting Challenges
Scope 3 emissions now include:
Transportation and logistics.
Use‑phase energy consumption.
End‑of‑life disposal.
To capture these, teams should adopt:
Supplier‑provided emissions data portals.
Carbon accounting software with Scope 3 modules.
Collaborative tools for joint emissions reduction initiatives.
Supply‑Chain Resilience Amid the Hormuz Crisis
The ongoing geopolitical tension in the Hormuz Strait disrupts oil‑derived feedstock shipments. Procurement strategies now focus on:
Geographic diversification of suppliers.
Investment in regional production hubs.
Implementation of digital traceability systems to monitor transit delays.
Preparing for H2 Procurement Cycles
Looking ahead, chemical buyers must:
Embed sustainability KPIs into contract terms.
Leverage AI for predictive supply‑chain risk modeling.
Engage in industry consortia to harmonize regulatory interpretations.
By aligning procurement practices with the evolving regulatory framework and supply‑chain realities, chemical teams can secure resilience, compliance, and market advantage.
Refined Glycerine 99.5% Min CAS: 56-81-5
