Under the SSDC rules of procedure adopted in 2004, social dialogue in this sector remains subject to considerable restrictions: it must not interfere in national industrial relations, it must not generate an additional level in the negotiation of collective agreements, and nor must it serve as an appeal body for the national social partners.

Sectoral social dialogue in the chemical industry explicitly rules out all mechanisms that would place companies or employees under any direct obligations. It is regarded by the employers more as a tool for lobbying the European institutions on sectoral policy matters (e.g. REACH; the Emission Trading System), whereas some of the trade unions affiliated to EMCEF would also like it to develop into a forum for issuing reciprocal commitments (on occupational diseases, social responsibility, etc.).

Under these circumstances, deemed by some to be too restrictive, certain players on the union side - both European and national - are trying to launch initiatives and proposals addressed directly to the European institutions (e.g. on the “cosmetics” directive) and to the major industrial conglomerates in the sector (e.g. the "Wittenberg” process in Germany, the attempt to negotiate a framework agreement on European social responsibility with the French conglomerate L’Oréal).

One might wonder, moreover, whether the strategy of the major chemical giants is geared more to the possibility of signing international framework agreements than towards overall sectoral social dialogue. Indeed, of the 60 or so international framework agreements logged by the ETUI, 12 were in the chemical sector (ICEM) and 8 of those involved European multinationals in the sector.

It has to be admitted that, despite the major developments that have occurred since the turn of the millennium, genuine European sectoral social dialogue based on reciprocal commitments is still a long way off in the European chemical sector owing to reservations on the part of the employers.