What Hiring Managers in Chemicals and Manufacturing Need to Know About the EU Pay Transparency Directive
The EU Pay Transparency Directive is changing how chemicals and manufacturing companies recruit and communicate salary across the UK and EMEA. Here’s what hiring managers need to know now.
The EU Pay Transparency Directive is changing how chemicals and manufacturing businesses recruit across the UK and EMEA. Salary has long been a late-stage conversation in this sector. Candidates come through a process, interest builds, and then a number appears, sometimes too low, sometimes misaligned with what the market has moved to, and occasionally a reveal that ends an otherwise strong hire before it starts.
The EU Pay Transparency Directive (2023/970) is designed to move that conversation to the beginning. For hiring managers across chemicals, manufacturing, lubricants, and specialty materials, the implications go beyond adding a salary line to a job posting.
From 7 June 2026, employers across the EU are bound by core obligations covering recruitment transparency, workers’ right to pay information, gender-neutral pay structures, and mandatory pay gap reporting.¹ The deadline has passed without full transposition in every member state, but the obligations stand. Since the first pay gap report is based on 2026 salary data, this compensation cycle may be the last opportunity to identify and address inequities before that data is locked in for public reporting.²
For businesses operating across the UK and EMEA, the picture is more complex still. UK employers are not directly bound by the directive, but multinationals with operations in EU member states, including Germany, France, the Netherlands, and Belgium, are subject to it regardless of where they are headquartered.³
Benchmarking is harder in this sector than many hiring managers acknowledge. A technical sales role in specialty chemicals, a process engineer in advanced coatings, or a formulation scientist in personal care ingredients, these are not roles with clean salary data sitting in a standard survey. Compensation varies significantly by specialism, geography, and the scarcity of sector experience.
Collective labour agreements in many EU countries are often sector-specific, including in chemicals⁴, which means pay transparency obligations will not sit in isolation. They will need to be read alongside existing CLA frameworks in markets like Germany and the Netherlands. That adds a layer of complexity that generalist HR teams are not always equipped to navigate.
The directive will make salary benchmarking significantly easier for candidates and may increase salary competition across employers, particularly in high-demand labour markets such as Germany and the Netherlands.⁵ For chemicals and manufacturing businesses already competing for a thin pool of experienced technical talent, that is a material shift in the dynamics of every hire.
The Recruitment Obligations in Practice
The core changes for hiring managers are straightforward in principle, even if the preparation takes time.
Employers must provide job applicants with information on the initial pay level or pay range before the first interview, and must not ask candidates about their previous salaries.¹ The salary range must be based on objective, gender-neutral criteria, including experience, responsibility, and working conditions, and employers must be able to demonstrate how those criteria were applied.
Where a pay gap within a worker category is 5% or more and cannot be justified by objective criteria, a joint pay assessment will be required.¹ For manufacturers with large workforces and long-established pay structures, that assessment process could surface some uncomfortable findings.
Pay gap reporting starts in 2027 for companies with 250 or more employees, in 2028 for companies with 150 or more, and in 2031 for those with 100 or more.⁶ The phasing gives medium-sized businesses some runway, but not on the recruitment transparency obligations, which apply now.
Do I need to add salary ranges to recruitment processes that were already underway before the legislation came into effect?
The short answer is: it depends on where the candidate is in the process.
The directive’s obligation is tied to the interview stage, not the date a role was posted. Salary range information must be provided before a first interview takes place. If a process started before June 2026 but a first interview has not yet happened, the safest approach is to provide the range before that interview goes ahead.
If a candidate is already past first interview, in final stages or moving toward offer, there is no explicit requirement in the directive to retroactively introduce a salary range at that point. The obligation appears to apply at the point of entering the interview stage, not retrospectively.
That said, the directive sets a baseline and individual member states can go further in their national transposition legislation. Rules may vary by country, and in markets like Germany and the Netherlands, the final local legislation is still being confirmed. For anything with direct compliance consequences, always verify with an employment lawyer familiar with the specific country’s requirements.
As a working principle: if the candidate has not yet been interviewed, include the range. If they are already in late-stage negotiation, the immediate compliance risk is lower, but disclosing it anyway remains best practice.
Can I still ask a candidate what they are currently earning?
No. The ban on salary history questions applies from the point the directive is in effect in each member state. Asking candidates about their current or previous salary is no longer permitted. Conversations about compensation should be anchored to the role’s salary range and the objective criteria used to set it, not to wherever the candidate happens to be coming from.
What if our salary range is genuinely hard to define, for example a highly specialist role with significant variation by experience level?
This is a real challenge in chemicals and manufacturing, where roles at the same title can vary significantly in scope and seniority. The directive does not require a single figure. It requires a range. But that range must be based on objective, gender-neutral criteria and cannot be so wide as to be meaningless.
The practical answer is to build your range from documented criteria: level framework, experience bands, responsibility scope, and market benchmarking data. A specialist recruitment partner with active market presence can help anchor that benchmarking to what candidates in your specific discipline are actually earning, which is a more defensible basis than broad salary surveys that aggregate too coarsely to be useful.
Companies that treat the salary range as a compliance formality, a band wide enough to mean nothing, set low enough to preserve negotiating room, will find it works against them. Candidates in technical disciplines talk to each other. A range that does not reflect market reality signals either a disconnect from the sector or a reluctance to be straight.
The businesses that get this right will use the requirement as a differentiator. A well-constructed, credible salary range for a technical sales manager or a process chemistry specialist tells candidates that you understand what that work is worth. Employers who fully embrace the changes may find themselves leading on transparency and fairness⁷, and in a candidate-short market, that reputation matters.
The practical challenge for many chemicals and manufacturing businesses is that building defensible, market-accurate salary ranges requires data that most internal teams do not have. Standard salary surveys aggregate too broadly. A “chemical engineer” range tells you little if the role sits at the intersection of formulation chemistry and technical sales in a niche materials segment.
A specialist recruitment partner with active presence in the sector, running searches, talking to candidates, and placing people across specialisms, carries compensation intelligence that is current, granular, and directly relevant to the roles you are trying to fill. That is the foundation you need to build ranges that are both compliant and competitive.
Companies should start preparing now. The directive requires salary ranges to be disclosed, equal pay for equal work to be ensured, and pay gap data to be reported.⁸ Waiting for full national transposition before beginning that work is a risk that will shorten your preparation window without improving your position.
Pay transparency is moving faster than legislation. Candidates in chemicals and manufacturing are already arriving at conversations with better market data, clearer expectations, and, once the directive is in full effect, the legal right to ask for pay information in writing.
The hiring process is becoming more transparent whether businesses are ready or not. The question is whether your compensation framework, your job postings, and the conversations your hiring managers have with candidates reflect that, or whether you are still operating on assumptions that no longer hold.
This is not a compliance task to hand to legal and forget. It is a prompt to look at how you value technical expertise, how you communicate that value to candidates, and whether your approach to salary is helping you hire the people you need or quietly sending them elsewhere.
The hiring process is becoming more transparent, whether businesses are ready or not. The question is whether your compensation framework, your job postings, and the conversations your hiring managers have with candidates reflect that or whether you are still operating on assumptions that no longer hold.
This is not a compliance task to hand to legal and forget. It is a prompt to look at how you value technical expertise, how you communicate that value to candidates, and whether your approach to salary is helping you hire the people you need or quietly sending them elsewhere.
Witan Search specialises in recruitment across chemicals, manufacturing, lubricants, and personal care across the UK and EMEA. If you are reviewing your hiring and compensation approach ahead of the EU Pay Transparency Directive, we are happy to share what we are seeing in salary benchmarks across your sectors.
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