All regulatory updates
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OEHHA republishes the current Proposition 65 chemical list dated Dec 5, 2025 (official downloadable list files)
OEHHA posted the latest consolidated 'Proposition 65 List' package (dated December 5, 2025) with downloadable formats (e.g., PDF/Excel/CSV). While this is not itself a new restriction, it is the authoritative consolidated reference used for Prop 65 applicability determinations; compliance teams should use this version (or any newer posted version) as the controlled reference for internal chemical screening and compliance checks.
OEHHA posts Proposition 65 list downloads reflecting the current list dated Dec 5, 2025
OEHHA updated/posted the current Proposition 65 chemical list download resources (PDF/Excel/CSV) on its Proposition 65 List webpage, with the list date shown as December 5, 2025. Compliance teams can use these official files as the authoritative reference for verifying whether a substance is listed and for maintaining internal restricted-substance/warning determinations.
OEHHA adds developmental toxicity endpoint to the existing Proposition 65 reproductive toxicity listing for bisphenol S (BPS)
OEHHA expanded the scope of the existing Proposition 65 reproductive toxicity listing for bisphenol S (BPS) by adding the developmental toxicity endpoint (effective December 8, 2025) via the State’s Qualified Experts mechanism (DARTIC). Compliance teams should reassess whether exposures to BPS trigger Prop 65 warning obligations considering the expanded reproductive toxicity endpoint and ensure warnings/supply chain communications remain accurate.
EPA releases new draft risk calculation memorandum for formaldehyde under TSCA and opens 60-day public comment period (until Feb 2, 2026)
EPA released an updated draft risk calculation memorandum and supporting documents for formaldehyde under TSCA and opened a 60-day public comment period (stated to run until February 2, 2026) via the TSCA docket on Regulations.gov. Compliance teams following TSCA risk evaluation work should review the draft methodology/assumptions and consider submitting comments, as approaches in the memorandum can influence downstream TSCA risk evaluation conclusions and potential risk management actions.
EPA opens 60-day public comment on updated draft risk calculation memorandum for formaldehyde under TSCA
EPA released an updated draft Risk Calculation Memorandum for formaldehyde under TSCA and opened a 60-day public comment period (noted as open until February 2, 2026). This is a technical support/analytical document that can influence how EPA quantifies and characterizes risk in the formaldehyde TSCA risk evaluation, which in turn can affect downstream risk management decisions and stakeholder engagement strategies. Compliance teams should review the draft methodology and submit comments if assumptions, exposure parameters, or calculation approaches affect their uses or conditions of use.
European Commission CRA summary page updated, reiterating staged application dates and the role of Annex I essential requirements in compliance evidence
The European Commission updated its CRA summary page (last update shown: 3 December 2025). The page reiterates CRA staged application dates and explains how manufacturers must evidence compliance with the Annex I essential cybersecurity requirements (baseline requirements) through risk assessment, technical documentation, and conformity assessment. This Commission-maintained summary supports compliance interpretation and program planning but does not change the legal text of Annex I.
ECHA guidance published for respondents to upcoming consultation on SEAC draft opinion for proposed EU-wide PFAS restriction
ECHA published consultation support materials for stakeholders preparing to respond to the forthcoming consultation on SEAC’s draft opinion regarding the proposed EU-wide REACH restriction on PFAS. The guidance explains how respondents should provide information during the planned consultation and is accompanied by a PFAS use-mapping annex to support structured submissions. Compliance teams should use these materials to prepare socio-economic and use-specific input for the upcoming restriction evaluation process.
CARB issues SB 261 Enforcement Advisory: enforcement paused due to Ninth Circuit injunction; Jan 1, 2026 deadline not enforced; alternate reporting date TBD
CARB published an Enforcement Advisory stating that, due to a Ninth Circuit injunction, it will not enforce Health & Safety Code § 38533 (SB 261) against covered entities for failure to post/submit climate-related financial risk reports by the statutory January 1, 2026 deadline. CARB indicates it will provide further information, including an alternate reporting date, after the appeal is resolved. This materially affects compliance planning and enforcement risk for in-scope entities, while leaving open voluntary reporting during the injunction period.
CARB Enforcement Advisory: SB 261 enforcement paused due to Ninth Circuit injunction; Jan 1, 2026 deadline not enforced; alternate date TBD
CARB issued an Enforcement Advisory stating it will not enforce Health & Safety Code § 38533 (SB 261) against covered entities for failing to post and submit climate-related financial risk reports by the statutory January 1, 2026 deadline because a Ninth Circuit injunction is in place pending appeal. CARB also indicated it will provide further information, including an alternate reporting date as appropriate after the appeal is resolved. This affects compliance planning by pausing enforcement risk for the statutory deadline while signaling that CARB expects reporting to resume on a revised timeline once litigation is resolved.
ECHA status document confirms March 2026 target for RAC opinion and SEAC draft opinion (followed by 60-day consultation) for EU-wide PFAS restriction
ECHA published a “current status/state of play” document for the proposed EU-wide PFAS restriction under REACH, outlining committee evaluation milestones. The document indicates a target for RAC to adopt its opinion and for SEAC to agree its draft opinion in March 2026, after which a 60-day public consultation on SEAC’s draft opinion is expected, with ECHA’s final opinion to follow later in 2026. Compliance teams tracking a potential broad PFAS restriction should use this schedule to plan for likely spring 2026 consultation participation and internal impact assessments, while noting this is not yet a binding restriction.
ECHA PFAS restriction evaluation status document outlines expected March 2026 committee milestones and planned 60-day consultation
ECHA published a PFAS restriction evaluation status document describing the anticipated REACH restriction process timeline for the broad PFAS proposal. The document states that RAC is expected to adopt its opinion in March 2026 and SEAC is expected to agree its draft opinion in March 2026, followed by a 60-day consultation on SEAC’s draft opinion and delivery of ECHA’s final opinion to the European Commission later in 2026. This is not a binding restriction change, but it is compliance-relevant because it signals when restrictions may crystallize and when stakeholders may be asked to respond to consultations.
Commission Implementing Regulation (EU) 2025/2392 adopted, setting technical descriptions for Annex III (important) and Annex IV (critical) product categories under the Cyber Resilience Act
The European Commission adopted Commission Implementing Regulation (EU) 2025/2392 to operationalize classification of ‘important products with digital elements’ (CRA Annex III) (and ‘critical products’ in Annex IV) by establishing technical descriptions for those categories. This directly affects Annex III compliance because classification as an Annex III ‘important product’ drives the applicable conformity assessment route (including stricter procedures for certain classes versus default self-assessment). Compliance teams should review product portfolios against the implementing regulation’s technical descriptions—focused on a product’s ‘core functionality’—to confirm Annex III applicability and the resulting conformity assessment obligations and documentation planning.
ECHA consultation on SEAC draft opinion for EU-wide PFAS restriction planned after March 2026 SEAC meeting (60 days)
ECHA published official information and supporting guidance indicating it plans to open a 60-day public consultation on SEAC’s draft opinion for the proposed EU-wide REACH restriction on PFAS after SEAC’s March 2026 meeting. This is a near-term stakeholder action point for companies to prepare socio-economic evidence, alternatives information, and confidentiality claims for the consultation submission process.
Commission Implementing Regulation (EU) 2025/2392 published, specifying technical descriptions for Annex III/IV product categories
The EU published Commission Implementing Regulation (EU) 2025/2392 in the Official Journal (OJ L, 1 December 2025). The implementing act sets out the technical descriptions of the categories of ‘important products with digital elements’ (CRA Annex III, Classes I and II) and ‘critical products with digital elements’ (CRA Annex IV). This is directly relevant to Annex III compliance because the clarified technical descriptions affect product classification, which in turn determines the applicable conformity assessment route and related compliance planning (e.g., whether stricter procedures apply for products falling under Annex III categories).
CARB Executive Order W-25-014 re-approves SGS Hong Kong Limited as a Third-Party Certifier (TPC-14) under 17 CCR §93120.4 (supersedes W-23-014)
CARB Executive Order W-25-014 re-approves SGS Hong Kong Limited as a CARB-approved Third-Party Certifier (TPC-14) under 17 CCR §93120.4 for the Composite Wood Products Formaldehyde ATCM (17 CCR §§93120–93120.12), superseding EO W-23-014. This is compliance-relevant because manufacturers subject to the ATCM must use CARB-approved TPCs to support certification/verification and ongoing surveillance. The EO continues SGS Hong Kong’s authority for hardwood plywood, particleboard, and medium density fiberboard and reiterates standard approval conditions (e.g., inter-laboratory study participation, subcontractor approval controls, annual reporting, record retention, and notice obligations).
ECHA Weekly highlights progress in RAC/SEAC evaluation of proposed EU-wide PFAS restriction (RAC opinion expected 2026)
ECHA reported (via its December 2025 RAC/SEAC meeting highlights) continued committee evaluation of the proposed EU-wide REACH restriction covering PFAS. This is a process milestone for stakeholders tracking the restriction: it signals the committees’ expected timing for adoption of opinions (including an expected RAC opinion in 2026 as stated in the ECHA update), which will inform later European Commission decision-making and any eventual compliance timelines.
CARB issues SB 261 Enforcement Advisory stating non-enforcement of Jan 1, 2026 deadline due to Ninth Circuit injunction; reporting voluntary pending appeal
CARB published an Enforcement Advisory for SB 261 stating it will not enforce Health & Safety Code § 38533 against covered entities for failure to post and submit climate-related financial risk reports by the statutory January 1, 2026 deadline, citing a Ninth Circuit injunction. CARB indicates SB 261 reporting is voluntary while the injunction is in place, and signals that further information (including an alternate reporting date) may be provided after the appeal is resolved. Compliance teams should continue preparing SB 261-aligned disclosures but should treat CARB enforcement for missed Jan 1, 2026 submission/posting as paused while monitoring for post-appeal updates.
ECHA highlights RAC/SEAC progress on EU-wide PFAS restriction; committees continue evaluating horizontal issues and restriction parameters
ECHA summarized December 2025 RAC and SEAC meeting highlights indicating continued committee examination of the proposed EU-wide PFAS restriction, including horizontal issues such as potential concentration limits and PFAS management/implementation considerations. For compliance teams, this provides an official status signal on how the restriction proposal is being refined (e.g., potential parameters/limits), which can affect future compliance planning for PFAS uses in products and processes.
ECHA reports progress and indicates RAC opinion expected March 2026 for EU-wide PFAS restriction
ECHA reported (via RAC/SEAC meeting highlights) continued evaluation of the proposed EU-wide PFAS restriction under REACH and communicated expected committee milestones, including RAC adoption of its opinion anticipated in March 2026, with SEAC draft opinion development and subsequent consultation to follow. This update is relevant for compliance planning and preparing for forthcoming committee opinions and stakeholder consultation steps, but it is not a final restriction or binding change yet.
CARB issues SB 261 Enforcement Advisory pausing enforcement of the January 1, 2026 reporting deadline due to Ninth Circuit injunction
CARB published an Enforcement Advisory stating it will not take enforcement action against covered entities for failing to post and submit SB 261 climate-related financial risk reports by the statutory January 1, 2026 deadline, citing a Ninth Circuit injunction against enforcement while the appeal is pending. CARB also indicates it will provide further information, including an alternate reporting date, after the appeal is resolved. Compliance teams should treat the statutory obligation as still on the books but recognize CARB’s stated enforcement posture and monitor litigation outcomes and CARB follow-on timing communications.