Why taking a closer look at the new EU Regulation is worth it
The EU’s tariff quota system may sound like a bureaucratic detail, but for chemical importers it has very real financial consequences. It defines which goods can enter the EU at reduced or zero customs duty and for how long these advantages apply. Those who understand and use tariff quotas can save significant costs, while those who overlook them risk paying more than expected and losing price stability.
The latest amendment, Regulation (EU) 2025/1292, defines the quotas and duty suspensions applicable from 1 July 2025. Future updates will continue to adjust these conditions regularly, meaning importers must closely monitor which chemicals benefit from reduced customs duty rates. Autonomous tariff quotas are designed to secure industrial supply and close production gaps within the EU. They are based on two key variables: quantity and time. Both determine whether an import remains duty-free.
Quantity and time determine the customs advantages of tariff quotas
Each tariff quota has a clearly defined limit. Once that limit is reached, the preferential treatment automatically ends, and the regular EU customs duty rate applies again. The same applies to timing. Many quotas are valid from 1 January to 31 December, including those that begin on 1 July and expire at the end of the year. Both factors determine whether an import remains duty-free.
Quantity limitation
Each quota has a clearly defined quantity limit. Once this amount is reached, the preferential treatment automatically ends, and the regular rate of the Common Customs Tariff applies again.
These quantities are precisely defined, for example:
1,000,000 tons of acetic acid
180,000 tons of paraffin
27,500 tons of L-(+)-lactic acid
57,500 tons of dimethyl terephthalate
30,000 tons of acrylonitrile
For importers, this means the duty saving is a limited quota shared across the entire EU. Those who register late may miss out.
Time limitation
Tariff quotas are also valid only within a specific period. Many run from 1 January to 31 December, while others, particularly new or amended ones, apply from 1 July 2025 and end on 31 December. These include, for example, the new quotas 09.2010, 09.2017, and 09.2024.
The interaction is crucial: the reduced customs rate applies only as long as the quota quantity has not yet been exhausted within the current quota period. If the quota is used up in October, the duty exemption ends for the rest of the year. The quota reopens only when the new period begins.
In practice, this means that the same product can be inexpensive in July and suddenly more expensive in November, even though raw material or transport costs have not changed.
Examples of tariff quotas in the chemical industry
The following overview lists typical chemical products for which the EU has established a tariff quota under Regulation (EU) 2025/1292. It shows how precisely both the quantitative and temporal limits are defined.
Quota No.
Product description (chemical substance)
Quota period
Quota quantity
09.2638
Acetic acid (CAS 64-19-7) with a purity of 99 GHT or more
1.1.–31.12.
1,000,000 tons
09.2679
Vinyl acetate (CAS 108-05-4)
1.1.–31.12.
370,000 tons
09.2828
Paraffin with an oil content of less than 0.75 GHT
1.1.–31.12.
180,000 tons
09.2540
Dimethyl terephthalate (CAS 120-61-6) with a purity of 95 GHT or more
1.1.–31.12.
57,500 tons
09.2742
Acrylonitrile (CAS 107-13-1) for the manufacture of products of Chapter 55 and heading 6815
1.1.–31.12.
30,000 tons
09.2700
Propan-1-ol (Propyl alcohol, CAS 71-23-8)
1.1.–31.12.
15,000 tons
09.2921
2-(Dimethylamino) ethyl acrylate (CAS 2439-35-2) with a purity of 99 GHT or more
1.1.–31.12.
14,000 tons
09.2567
Trichloroethylene (CAS 79-01-6) with a purity of 99 GHT or more
1.1.–31.12.
11,885 tons
09.2017
L-(+)-Lactic acid (CAS 79-33-4) for pharmaceutical purposes
1.1.–31.12.
27,500 tons
09.2024
Tetrahydro-2-methylfuran (CAS 96-47-9) with a purity of 99 GHT or more
1.1.–31.12.
750 tons
Once the quota quantity is exhausted, the regular customs duty applies to all remaining imports, even if contracts were signed earlier in the year.
When calculation becomes a balancing act
This is where the greatest risk in purchasing arises. Many companies plan their sales prices based on purchasing conditions without customs duties. However, if the quota is exhausted during the year, the full customs duty suddenly applies, often between five and six percent.
This immediately changes the calculation. Price lists must be adjusted and margins reviewed. In practice, this can mean that an identical product becomes more expensive in the next quarter even though raw material prices or transport costs have not changed.
Anyone responsible for purchasing should therefore regularly check not only raw material prices but also the availability of tariff quotas.
Duty-free importation only through active registration
The exemption from customs duties does not apply automatically. To apply the zero rate, the importer must indicate the correct CN code, TARIC code, and the quota number when submitting the customs declaration.
The decisive point in time is the acceptance of the customs declaration for release for free circulation. It is not the date of order or shipment, but the actual registration that determines whether quota volume is still available.
If the EU-wide quota quantity is exhausted, the full duty rate applies even if the contract was signed long beforehand. The margin impact can be immediate.
End-use and monitoring
Many chemical products listed in the regulation are subject to monitoring by customs authorities regarding their end-use. The importer must declare for what purpose the imported goods will be used.
Examples:
L-(+)-lactic acid may only be used for pharmaceutical applications.
Octadecyl-3-(3,5-di-tert-butyl-4-hydroxyphenyl) propionate may only be used for polymer stabilizers.
Acrylonitrile may only be used for the manufacture of defined chemical products.
Those who fail to comply with the requirements or cannot provide evidence risk subsequent claims and fines.
Geopolitical restrictions on duty-free imports
In line with the EU’s sanctions policy, tariff quota exemptions no longer apply to goods originating from Russia or Belarus. The products affected include paraffinic residues (No. 09.2600), acrylonitrile (No. 09.2742), C.I. Pigment Red 4 (No. 09.2698), and aluminum bars of alloys (No. 09.2835).
Since 1 July 2025, these products are again subject to the regular customs rate. For companies importing chemicals from China or other third countries, this highlights the need to diversify sourcing and closely monitor regulatory changes.
Practical recommendations for chemical importers
Autonomous tariff quotas directly influence sourcing economics. When managed actively, they protect purchasing budgets and price stability. When overlooked, they erode margins and predictability.
Monitor quotas regularly Track which chemical products fall under a tariff quota and how much volume has already been used.
Prepare customs declarations carefully CN code, TARIC code, and quota number must be entered correctly.
Adjust calculations and price lists When a quota is exhausted, additional costs arise from EU customs duty. These must be immediately reflected in pricing.
Document end-use For goods subject to end-use monitoring, evidence of actual use is required.
Diversify supply sources For geopolitically affected goods, identify alternative producers and origins early.
Why this matters for chemical buyers
Autonomous tariff quotas may look like a line in the customs register, but they directly shape sourcing economics.
When managed actively, they protect purchasing budgets and stabilize pricing. When overlooked, they quietly erode margin and predictability.
For procurement teams, this means one thing: monitoring quantities, periods, and registration timing is just as important as tracking raw material prices.
At CheMondis, we follow regulatory updates such as Regulation (EU) 2025/1292 to help buyers make informed, data-based decisions that keep sourcing both compliant and competitive.
Source:
Council Regulation (EU) 2025/1292 of 24 June 2025 amending Regulation (EU) 2021/2283 Official EUR-Lex reference: can be found here.
Sourcing Compliant PU Adhesives Under EU Diisocyanate Restriction
For European chemical buyers and suppliers, the EU diisocyanate restriction under REACH. It took effect in August 2023, has reshaped the adhesives landscape. Companies that relied on polyurethane (PU) adhesives have already decided. Whether to invest in ongoing employee training to stay compliant or to transition to safer, isocyanate-free alternatives.
While many large players acted early, a surprising number of small and mid-sized businesses are still catching up, managing compliance, optimizing their sourcing, and exploring better-performing options. This article takes stock of how the industry has shifted since 2023 and what buyers should know about today’s alternatives and innovations in safer adhesive formulations.
The EU Diisocyanate Restriction and Why It Matters
The EU’s REACH restriction, effective August 24, 2023, mandates training for handling adhesives with more than 0.1% diisocyanates. The rule was introduced for good reason because diisocyanate chemicals, found in PU foams and adhesives. That can cause skin irritation, allergies, and even occupational asthma. In fact, over 5,000 cases of work-related illness from diisocyanate exposure were reported in Europe in a single year.
To curb these hazards, the EU now requires that any industrial or professional use of products containing more than 0.1% diisocyanates by weight must come with comprehensive training and certification for the workers involved. This training is not a one-time box to tick. It must be renewed at least every five years and conducted by qualified experts.
For European companies relying on PU adhesives, the implications are immediate. You can still use your go-to adhesive, but not without investing time and resources into employee training and compliance documentation. The rule has impacted many industries, from automotive to construction, where PU adhesives are common.
Exploring Alternatives to PU Adhesives
As companies move away from traditional polyurethane adhesives, a growing range of safer, isocyanate-free formulations has emerged. Some are well-established and others are more innovative. Epoxy adhesives remain a go-to for high-strength structural bonding, offering durability and excellent impact resistance, though they require careful mixing and have a set working time.
Acrylic adhesives, often methyl methacrylates, are prized for fast curing, strong bonds on metals and plastics, and the ability to join dissimilar materials without primer, making them a versatile alternative. Cyanoacrylates, or “super glues,” have also evolved with tougher, odorless variants that are more resilient and workplace-friendly, well-suited for quick, mid-strength bonds. Silane-modified polymers (SMPs) combine the elasticity of silicones with the strength of polyurethanes in a paintable, solvent-free, moisture-curing formulation that is ideal for construction and automotive applications.
Finally, bio-based adhesives derived from renewable materials like starch, lignin, or vegetable oils are gaining traction for lightweight, non-structural uses and appeal to sustainability goals, though they are not yet as strong as synthetic alternatives. Each formulation has trade-offs, but the key takeaway is this: sourcing adhesives that comply with the EU diisocyanate restriction no longer means compromising on performance.
Why Sourcing Feels Complicated
Switching products is one thing. Finding the right supplier, ensuring compliance documentation, and coordinating across regions, that’s where complexity often slows teams down.
Even buyers who know what alternatives they want often find themselves limited to a handful of familiar suppliers. But there are often many more suitable options available; they’re just harder to find or vet.
Embracing Change and Staying Ahead
Nearly two years after the EU diisocyanate restriction came into force, the adhesive market has moved, but not everyone has fully caught up. Buyers who adapted early have already reaped the benefits of safer, more innovative adhesives, while others are still navigating the transition or fine-tuning their sourcing strategies. What hasn’t changed is the complexity: finding the right product, ensuring it’s truly compliant, and uncovering all your supplier options still takes time and expertise.
CheMondis combines digital tools with hands-on support to help you stay ahead, bringing you not just the three suppliers you know, but the twenty-two you didn’t know you were missing. Explore how we can help you close the gap between regulatory compliance and competitive advantage, without sacrificing performance or peace of mind.
Sources:
European Chemicals Agency (ECHA)
FEICA – Association of the European Adhesive & Sealant Industry
At CheMondis, we help procurement teams manage the EU BPA ban supply chain challenge by connecting them with verified suppliers of compliant alternatives. The transition away from BPA is complex, but you don’t have to navigate it alone. CheMondis provides the market intelligence and supplier access you need to de-risk your sourcing strategy
This is a complete and total ban, not a partial restriction. It covers everything from the coatings inside a food can to the printing ink on a bakery bag. Previous restrictions on BPA, such as the one for baby bottles, were narrow. This new ban is broad and all-encompassing, affecting plastics, coatings, resins, adhesives, and more.
Your key suppliers are being forced to change, and if you’re not proactive, you risk being caught off guard.
EU BPA Ban Supply Chain Pain Points for Procurement
You’ve relied on BPA for years because of its reliable performance. It’s durable, heat-resistant, and provides the barrier properties essential for food safety and shelf life. But now the EU BPA ban supply chain compliance process raises critical questions.
Supplier Risk: Are your current suppliers ready for this? Are their “BPA-free” claims legitimate, or are you buying non-compliant stock?
Cost & Scalability: Can compliant alternatives match the performance of BPA without skyrocketing costs? Are these new materials available at the scale you need?
Operational Disruption: How do you manage the transition? The clock is ticking on transitional periods, and once they expire, you need a new sourcing strategy, or your production lines could grind to a halt.
Pressure isn’t just coming from regulators; it’s also coming from your customers, who are demanding safer, “clean-label” products.
Why is This a Challenge in Supply Chain?
BPA has been a go-to material for decades because it’s:
Durable and heat-resistant
Excellent at forming protective barriers
Critical to safety and extending shelf life
For business the important question becomes:
Which materials can safely and legally replace BPA?
Are the alternatives scalable and cost-effective?
How do we transition production without disrupting supply?
While the regulation includes transitional periods to use up existing stocks, pressure from regulators, buyers, and consumers to switch BPA-free products is already here.
How to Secure Your Supply Chain After the EU BPA Ban
This ban is a catalyst for innovation and a chance to build a more resilient supply chain. The EU’s Safe and Sustainable by Design (SSbD) initiative is already pushing the market toward safer, high-performing alternatives. Forward-thinking companies are already sourcing:
Next generation coatings: BPA-free and PFAS-free solutions for food packaging Innovative polymers: Bio-based, compostable, and recyclable materials Compliant adhesives and inks: Products that meet stringent EU health and safety standards.
By taking immediate action, you not only guarantee compliance but also enhance your market positioning. You are not merely avoiding risks; you are constructing a supply chain that is resilient and prepared for the future.
Your Sourcing Partner
The EU’s BPA ban marks a turning point for food-contact materials — and for the entire food and packaging supply chain. Companies that act now to find and adopt safer, compliant alternatives will not only avoid last-minute disruption but also position themselves as leaders in sustainability and food safety.
CheMondis is here to help you stay ahead with the right materials, from the right suppliers, at the right time.
Instead of navigating fragmented supplier lists and unverified claims, CheMondis provides a centralized, transparent platform for chemical procurement. At CheMondis, we understand that replacing BPA in food-contact materials isn’t just about compliance — it’s about finding innovative, sustainable solutions without compromising on performance.
In 2025, cosmetic ingredient sourcing in Europe is at a turning point. A wave of regulatory change is coming, which Cosmetics Europe calls a “regulatory tsunami”. REACH revisions are due by the end of 2025, and updates to the EU Cosmetics Regulation are expected soon. At the same time, documentation demands are increasing. For procurement teams, the stakes are high: can you trust the documents you receive, or will gaps lead to disruptions?
Regulatory Overhaul for Cosmetic Ingredient Sourcing
The European Commission is reviewing the EU Cosmetics Regulation 1223/2009. A REACH reform proposal is also in progress. This includes shorter registration validity (ten years), expanded polymer requirements, and mandatory Digital Product Passports (DPPs).
Changes like Commission Regulation (EU) 2025/877 will start on 1 September 2025, tightening bans on CMR substances and other ingredients.
GMP Expectations Remain High:
EU law (Regulation 1223/2009, Article 8) requires adherence to Good Manufacturing Practices. Compliance with ISO 22716 shows GMP conformity.
Documentation Obligations:
Responsible Persons must keep detailed Product Information Files (PIFs). This includes safety assessments, CoAs, and proof of GMP compliance, accessible for at least ten years.
Supply chain documentation is rising as firms prepare for more digital tools like DPPs and digital SDS.
Key Challenges for Procurement Teams in 2025
Regulatory Complexity & Shifting Deadlines
Multiple reforms (Cosmetics Regulation, Fitness Check, and REACH updates) create fluid timelines, making supplier documentation delays risky.
GMP Certification Ambiguity
Not all suppliers adopt ISO 22716 or provide the necessary PIF documentation. This leaves procurement unsure if products meet GMP standards.
REACH and Registration Validity Risks
If supplier REACH dossiers lose validity, procurement may struggle to find compliant alternatives, especially as registration periods shrink.
Inconsistent CoAs and Chain-of-Custody Data
Variations in formats and completeness hinder internal reviews, especially regarding chain-of-custody transparency.
How CheMondis Strengthens Cosmetic Ingredient Sourcing
CheMondis offers a technology-enabled, expert-backed supplier discovery platform that clarifies documentation without overpromising.
AI-Powered Data Aggregation: Quickly access supplier information globally, highlighting GMP compliance (per ISO 22716), REACH registration status, and CoA availability.
Transparent Supplier Profiles: Differentiate between manufacturers and intermediaries, show chain-of-custody details, and flag potential weaknesses (e.g., approaching REACH expiry).
Balanced Sourcing Support: Connect with global suppliers while meeting European documentation standards
With CheMondis, procurement teams gain greater supply chain compliance visibility, enabling quick, confident sourcing decisions.
Practical Steps for European Procurement Teams
Use a Documentation Checklist
Current REACH registration numbers, CoAs, and indications of DPP or digital SDS when relevant.
Prioritize Supplier Transparency
Note if the supplier is the manufacturer or a distributor. Request upstream documentation or audit evidence.
Track Regulatory Reform Timelines
Align sourcing cycles with known deadlines, like REACH reform or the 1 September 2025 implementation of Regulation 2025/877.
Mitigate Supply Risk with Verified Partners
Especially when sourcing from high-volume markets, they require documented REACH compliance, chain of custody evidence, and timely CoAs to reduce disruption risk.
Strategic Takeaway: Turning Documentation into Competitive Advantage
In 2025, successful cosmetic ingredient sourcing in Europe depends less on price and more on the ability to verify documentation and compliance proactively. Uncertainties around GMP, REACH registration, and ingredient bans require clear visibility. Procurement teams that can quickly assess and trust supplier documentation will position their brands ahead of disruptions.
The EU Deforestation Regulation (EUDR) will be enforced in December 2025. Food manufacturing procurement managers have a choice: adapt their supplier networks for traceability or risk losing market access.
The EUDR is more than a sustainability guideline. It sets legal duties for all operators and traders who sell relevant products in the EU market. The focus is now on raw materials. This includes high-risk commodities such as cocoa beans, green coffee, soy, and palm oil. These ingredients typically come from regions with intricate land use histories. They also involve informal value chains and have poor documentation.
While enforcement has been delayed from its original December 2024 deadline, this shift has not removed pressure. Supplier qualification and documentation alignment have only grown more urgent.
The EUDR Compliance Landscape: Why Raw Materials are in Focus
The EUDR seeks to cut the EU’s role in global deforestation. By doing so, EUDR makes sure that products sold are deforestation-free and legally made. It targets seven key commodities: cocoa, coffee, soy, palm oil, rubber, timber, and cattle.
The regulation explicitly includes both primary goods and derivative products. For food manufacturers, this means a range of raw and semi-processed ingredients now fall under scrutiny. Examples include:
Cocoa beans and semi-finished cocoa mass from Côte d’Ivoire, Ghana, and Nigeria
Green coffee from Brazil, Colombia, and Vietnam
Crude and refined palm oil from Indonesia and Malaysia
Soybeans and soy derivatives (e.g., soybean meal, protein concentrate) from Brazil and Argentina
These materials are the key ingredients in many food products. They are used in sweets, baked goods, dairy, and meat substitutes. If they can’t be linked to a specific farm that was deforestation-free as of December 2020, they won’t meet EU compliance standards anymore.
In July 2025, the European Parliament rejected the Commission’s plan for a country risk classification system. This system would have labeled some origins as “low risk.”
As a result:
No countries currently benefit from an exemption.
Every operator must perform full due diligence on every relevant shipment.
Traceability down to the plot of land remains mandatory.
Procurement Challenges: Raw Material Compliance in Practice
EUDR enforcement affects multiple stages of procurement. Among the most pressing issues for raw material buyers:
Lack of mappable farm-level data Many smallholders in origin countries do not currently have geo-coordinates, digital land deeds, or deforestation-free certifications.
Reliance on fragmented supplier networks Brokers, traders, and cooperatives may lack visibility into the exact source of raw materials. This complicates traceability.
Limited documentation culture Legal origin proof and land-use verification often exist in non-standardized formats, or not at all. Procurement teams must validate and standardize data across diverse sources.
Legacy relationships without compliance guarantees Longstanding supplier partnerships may offer reliability in logistics or pricing; however, they do not offer documentation. EUDR raises the bar.
Increased customs disruption risk Incomplete or non-compliant due diligence documentation can result in shipment holds, reputational risk, and financial losses.
How CheMondis Supports Raw Material Procurement Teams
At CheMondis, we help sourcing teams meet new regulatory demands. CheMondis provides structured and verified access to suppliers. Connects buyers and suppliers. Moreover, we also offer clarity, help with compliance, and boost decision-making confidence.
Here’s how:
Pre-qualified Supplier Data Our supplier profiles show:
Traceability
Export capability
Focus on upstream visibility We connect you to manufacturers of certified cocoa mass, crude palm oil, and green coffee beans. All have clear sourcing chains.
Custom discovery workflows We provide a structured longlist of suppliers for each request. EUDR-relevant criteria are highlighted clearly.
Ongoing regulatory alignment We continuously monitor regulatory updates to ensure our verification processes and supplier insights remain aligned with EUDR expectations.
EUDR compliance is about more than avoiding legal trouble; it’s about safeguarding access to the EU market and ensuring the long-term sustainability of your sourcing strategy.
By preparing early, demanding supplier transparency, and building traceability infrastructure now, food manufacturers will be in a stronger position when enforcement begins.
At CheMondis, we help you stay ahead of the curve.
