It’s a particularly dizzying time to be in the chemicals industry, with companies being squeezed from two directions simultaneously. On one side, there’s a regulatory environment that is reorganizing, accelerating and, in some cases, fracturing into a patchwork of state and federal requirements that do not always work in concert. On the other side, there’s a raw materials landscape where the definition of a viable input is changing, driven by circularity mandates, sustainability reporting pressure and genuine advances in what recycled feedstocks can deliver.
GlobalChem 2026, the American Chemistry Council’s global chemical regulations conference held in late February, put a sharp lens on the regulatory half of that picture. A separate SmartBrief conversation with Eric Dumain, global market director for coating resins at Arkema, offers a practitioner view of what the materials side looks like from inside a company that has been building toward this moment for years. Together, they sketch something close to a full picture of where the industry actually stands.
The regulatory machine is reorganizing and early engagement is the new leverage point
The headline out of GlobalChem was capacity: EPA absorbed 35 additional experts through reorganization, added 50 more scientists to a new Risk Assessment Support Division, and is projecting 10 completed risk evaluations in 2026 alone, up from five in 2024.
EPA deliberately reorganized so that research functions now live inside the same office responsible for regulatory decisions. The new division is an attempt to close the gap between generating scientific data and actually using it in enforceable requirements. That distinction matters because the historical bottleneck in chemical regulation has rarely been a shortage of science. It has been the distance between science and action. For industry, the implication is that early engagement is no longer optional best practice. It is the primary lever available for shaping how a risk evaluation unfolds. EPA director Elissa Reaves said it plainly at the conference: early engagement is key from scoping to peer review. The reorganization is designed to make that engagement more consequential, not just more frequent.
The backlog story is hiding a process problem
Data on Premanufacture Notice review times told a story that could be interpreted as a backlog problem or a process design problem. Average PMN review time since 2016 sits at 520 days. The 2025 median for Significant New Use Notifications, which cover new uses of chemicals already reviewed, has reached 934 days. SNUNs are theoretically narrower in scope than full PMN reviews. They are taking nearly twice as long.
That asymmetry suggests the program has not optimized its process for a submission type that is becoming more common as the chemical inventory matures. More chemicals in commerce means more new uses, which means more SNUNs. The agency is staffing up for the workload it had. The workload it is getting may require a different approach entirely.
For companies planning new applications for existing chemistries, the SNUN timeline is the more operationally relevant number and it is moving in the wrong direction.
State PFAS timelines are tightening faster than federal coordination
While federal review timelines stretch, state-level regulation is accelerating on a parallel track. Maine, Minnesota and New Mexico now regulate PFAS across all product categories, with most uses restricted by 2032 unless designated currently unavoidable. Minnesota and New Mexico have reporting deadlines within the next 12 months. New Mexico proposed labeling requirement takes effect in January 2027.
The compliance risk is layered. Regulatory enforcement, such as penalties, market access barriers and testing obligations, compose the visible layer. The less-discussed layer is litigation. Publicly available reporting data does not stay in regulatory files; it becomes available for product liability discovery. NGOs and media treat disclosure data as a consumer influence tool. The plaintiff bar is already structuring cases around it.
The practical advice from environmental attorneys at the conference was direct: Run due diligence in tandem with outside counsel, not sequentially. By the time you know what you have to disclose, it is too late to manage the downstream exposure separately.
Recycled feedstocks are arriving just as regulators start demanding them
The regulatory pressure on raw material choices is arriving at exactly the moment when recycled feedstocks are becoming technically credible, and that timing is not coincidental. It is the result of a decade of investment by companies like Arkema, which has been integrating post-consumer recycled PET into powder coating resins and currently incorporates up to 40 percent rPET in certain formulations.
The distinction Dumain draws between pre- and post-consumer rPET matters for anyone evaluating sustainability claims in the coatings space. Pre-consumer material is manufacturing scrap that never reached end use — cleaner and easier to work with, but limited in circularity contribution. Post-consumer rPET comes from waste streams that can no longer be mechanically recycled back into packaging or bottles. Using it in powder coating resins diverts material that would otherwise become waste and contributes to a measurable reduction in CO2.
The technical barriers to pushing that percentage higher are real but narrowing. Higher recycled content can reduce UV stability in exterior applications and may introduce compatibility issues as small impurities interact with other coating ingredients. Dumain sees both improving as waste streams become more tightly controlled and color separation technology advances.
“In some of our applications testing, we see better results in chemical and hardness development vs a reference standard,” Dumain told SmartBrief. “So incorporating recycled content can in some instances actually boost end use performance while diverting resources away from landfills.”
Performance and sustainability are converging
One of the more counterintuitive findings from both sources is that the sustainability story and the performance story are beginning to converge. And not because the industry decided they should, but because the materials science is forcing it.
Powder coatings already carry inherent sustainability advantages: low VOCs, minimal waste, no solvent emissions. Adding rPET content compounds that story rather than diluting it, provided the documentation is rigorous enough to support the claim at each step in the value chain. What Dumain describes in Arkema testing (recycled-content products outperforming virgin-material references on chemical resistance and hardness) is the data point that shifts the conversation from sustainability premium to performance parity.
The GlobalChem sessions showed a parallel dynamic on the regulatory side, where New Approach Methods — non-animal testing protocols driven by AI and computational toxicology — are being validated not just as ethical alternatives but as faster and in some cases more scientifically precise tools than traditional animal studies. EPA Administrator Zeldin committed in January 2026 to eliminating all mammal study requests and funding by 2035. The NCD new skin irritation and corrosion decision framework already prioritizes human cell-based models over animal data.
For the chemicals industry, the implication is the same whether the subject is rPET in powder coatings or AI in toxicology: the next-generation approach is no longer asking permission to compete on performance. It is starting to win on performance.
The economics are still catching up, but the trajectory is defined
The economics of circularity are still catching up to the science and the regulation. Dumain is candid about where the cost burden currently sits: Early-stage adoption means companies in the resin space and downstream are absorbing costs the broader system has not yet priced in. Fossil fuel production carries subsidized externalities that recycled-content production does not offset through comparable incentives.
His read on the trajectory echoes what the chemicals industry heard at GlobalChem on regulatory certainty: once the learning curve normalizes and the economics reach parity, market-driven demand takes over from policy-driven adoption. The analogy to renewable energy is apt. The question is how long the transition period lasts and who bears the cost during it.
For large formulators, Dumain points to European supply chains as the model for de-risking recycled feedstock supply. The goal is to normalize post-consumer industrial streams the way paint recycling has become normalized in some markets. That is not a short-term project, but it is a defined path.
The chemicals industry in 2026 is navigating simultaneous pressure from regulators moving faster and demanding more, and from a raw materials landscape changing what a responsible input looks like. The companies farthest along, on both sides of that equation, are the ones that stopped treating those pressures as separate compliance problems and started treating them as a single strategic question about what the industry is building toward.
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