When Change Becomes a Never-Ending Task
30 Years of Responsible Care in the Chemical Distribution — On the Difference Between the Ability to Drive Change and the Capacity for Development
Industry commentary | Alison Marburger | October 14, 2026
An anniversary that reveals two truths
“Responsible Care was never intended to be a project, but rather a process.” This thought from Reinhard Friedek’s anniversary speech at the Responsible Care workshop hosted by the German Chemical Trade Association in Cologne has particularly stuck with me. It precisely describes what has distinguished the initiative for 30 years: the commitment to continuously improve safety, health, and environmental protection beyond mere compliance with legal requirements. Since 1996, the chemical trade sector in Germany has been committed to this path. ¹ This is no trivial anniversary, but a remarkable achievement.
In Cologne, this sense of pride was clearly evident. These were people who had gained decades of experience, established rigorous procedures, and not only accompanied change but actively shaped it themselves. There were lively discussions, knowledge was shared, and solutions were worked on. At the same time, I sensed a different mood: tension, and in some cases fatigue, in the face of the question of how the next wave of documentation, testing, and information requirements is to be managed. These two impressions do not contradict each other. Their coexistence is my actual observation.
After all, when an industry, which has demonstrated its willingness to pursue voluntary improvement for decades, is increasingly struggling to meet the requirements for such development, the usual question about a lack of willingness to change falls short. I wonder if we’re overlooking another, less visible limitation: limited organizational capacity for development.
Not every change is development
In the debate over regulation, costs, processing times, and administrative obligations are taken into account. This is necessary, but it does not fully explain what is happening within companies. New requirements do more than just alter to-do lists. They disrupt well-established structures of expertise: specialists must interpret regulations, clarify responsibilities, tap into data sources, integrate suppliers, modify ERP processes, reorganize controls, and ensure implementation in day-to-day operations.
This doesn't mean that existing expertise is suddenly lost. However, certainty in performing tasks can be temporarily lost: The previously stable combination of knowledge, routines, systems, and responsibility no longer fully aligns with the new conditions. This alignment needs to be reestablished. In fast-paced environments, these cycles repeat before the previous adjustments have fully taken root in day-to-day operations.
This is where my first thesis comes in: Regulatory change does not merely consume resources for its implementation. It also ties up an organization’s ability to continually reestablish professional confidence.
Coping is not the same as development
This brings us to a second crucial distinction: Change management is not automatically development. A company can train people, restructure processes, establish new verification chains, and make substantial investments. That constitutes significant change management. Nevertheless, the result may merely be a return to reliably meeting the minimum standards now in effect. The organization has changed without necessarily creating additional scope for innovation, better collaboration, or strategic advancement.
This is not meant to devalue compliance. Especially in the chemical trade, it is a basic requirement for safety, reliability, and market participation. The problem arises when we interpret the successful navigation of ever-new requirements as proof of a successful transformation. For then we overlook how much developmental energy was expended simply to return to the starting point of a functioning organization.
Therefore, my second thesis is this: We could interpret part of an organization’s coping performance as transformation, even though it primarily serves to restore the capacity to act under changed conditions. The performance is real; its developmental outcome is another question.
When reasonable goals compete with one another
This tension can be illustrated by two real-world discussions. First, political representatives have essentially suggested that the chemical trade industry could benefit from using additional compliance and documentation services as a unique selling point. This is not strategically unreasonable: reliable information and secure supply processes have value. Anyone who reliably masters complex requirements provides a valuable service. However, whether this translates into a monetizable competitive advantage is determined not by the theoretical quality of the service, but by the market. If customers require identical documentation from all suppliers, the service becomes a necessary condition of the business relationship. Providing this documentation involves effort; however, meeting these requirements does not automatically create a willingness to accept additional costs. This difference is crucial in an industry under economic pressure. Regulatory-driven additional costs may be economically necessary and socially meaningful without translating into additional revenue.
Similar contradictions can arise from the demand for more resilient supply chains: Diversifying supply chains is rightfully seen as a path to greater resilience. Additional sources of supply can reduce dependencies. At the same time, they increase the number of relationships to manage, interfaces, and, where applicable, the legal jurisdictions that must be navigated. Resilience achieved through strategic measures can initially increase operational complexity and vulnerability to failures. This is not an argument against diversification, but rather against considering individual goals in isolation from their interactions.
Readiness is not capacity
The economic situation is intensifying these tensions. According to Cefic’s Chemical Trends Report dated October 5, 2026, chemical production in the EU fell by 2.0 percent from January through July compared to the same period last year. Weak demand and structural competitive pressure persist. These figures do not fully explain the situation in the chemical trade; however, they illustrate the European environment in which many of its customers and suppliers operate.²
My third and broader thesis is therefore a question about our conception of transformation: Perhaps we talk too often about companies’ willingness to change and too rarely about the limits of their capacity for change.
Willingness is an attitude. Capacity consists of time, personnel, money, knowledge, attention, and the ability to implement changes sustainably. These two are not interchangeable.
This distinction is not merely semantic. Those who focus solely on the timely implementation of a requirement fail to see which projects have been postponed, which improvements have been delayed, and which learning processes have been interrupted. Such opportunity costs cannot be quantified in general terms, nor can they be empirically proven based on a single event. But they are relevant to long-term performance and innovation capacity.
What Remains from Cologne
I left Cologne without any quick fix. And I definitely don't want to use these observations to make any further demands upon an industry that is already delivering a huge amount. Nor did I get the impression that the chemical trade is avoiding its responsibilities. On the contrary: the openness of practitioners in comparing experiences, questioning positions, and striving for workable approaches was proof of what Responsible Care has made possible over three decades.
The exchange within associations and working groups—conducted responsibly from both a technical and antitrust perspective—is not merely a decorative side event. It creates spaces where different corporate realities can come together, where practical knowledge is shared, and where collaborative learning becomes possible. It would be that much more valuable if this practical perspective could also be incorporated where regulatory frameworks are being developed and their impact on companies can still be shaped.
During this day, I was particularly moved by the coexistence of great technical expertise, palpable fatigue, and a sincere desire for further development. Thirty years of Responsible Care are a reason to be proud of what has been achieved. At the same time, this anniversary raises the question for me: under what conditions this development process might be able to continue in the future.
Perhaps we do not need another call to action at this point, but rather a more precise distinction: How can we maintain the capacity for continuous improvement when more and more of our capacity for change is being consumed by restoring whatever new minimum standard is in place?
My concern is not a lack of willingness to take responsibility. It is the question of how much room still remains, under current conditions, for a demonstrably existing willingness to pursue further development.
Sources and Methodological Context
¹ Verband Chemiehandel e. V., Responsible-Care-Programm: https://www.vch-online.de/nachhaltigkeit/responsible-care/programm
² Cefic, Chemical Trends Report Q3 2026, 5. Oktober 2026: https://cefic.org/news/cefics-chemical-trends-report-q3-2026-is-out/
The descriptions of the workshop reflect the author’s personal impressions. The conclusions drawn from them are technical hypotheses, not empirically proven causal relationships.