All regulatory updates
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UK publishes Year 2 illustrative waste disposal fees with RAG eco-modulation
UK government published Year 2 illustrative waste disposal fees under the Extended Producer Responsibility for packaging scheme. The fees introduce eco-modulation using Recycling Assessment Methodology (RAM) with Red/Amber/Green (RAG) ratings: Green fees offer ~9% discount for recyclable materials, Amber represents base rate, and Red fees carry a 20% premium for less recyclable materials (increasing to 2x by Year 4). Confirmed Year 2 fees are expected to be published in June 2026 following the April 1, 2026 reporting deadline.
OEHHA issues request for relevant information on carcinogenicity of ethoprop (CIC review for possible delisting)
OEHHA posted a request for relevant information on the carcinogenicity of ethoprop and indicated the substance is being referred to the Carcinogen Identification Committee (CIC) for review for possible delisting. This initiates a stakeholder input/data submission process that could ultimately lead to a delisting decision. Compliance teams using ethoprop in products or operations should monitor the review, consider submitting relevant toxicology/exposure data, and be prepared to adjust Prop 65 warning determinations if OEHHA proceeds with delisting or maintains the listing.
OEHHA issues request for relevant information on carcinogenicity of ethoprop (potential delisting review)
OEHHA posted a Request for Relevant Information on the carcinogenicity of ethoprop, indicating the chemical is being referred to the Carcinogen Identification Committee (CIC) for review for possible delisting from the Proposition 65 list. This is not a final delisting, but it is an official step in the delisting evaluation process and invites stakeholders to submit relevant data within OEHHA’s stated information-request window. Compliance teams tracking Proposition 65-listed substances should monitor this proceeding because it could eventually change listing status and related warning/enforcement exposure for ethoprop.
NY prohibits PFAS and toxic chemicals in menstrual products
New York enacted legislation (S.1548/A.1502) prohibiting the sale and distribution of menstrual products (pads, tampons, liners, sponges) containing PFAS 'forever chemicals,' heavy metals (lead, mercury), hormone-disrupting parabens, carcinogens (formaldehyde, toluene), triclosan, talc, phthalates, and synthetic fragrances. The law is among the most stringent menstrual product regulations in the United States.
European Commission posts updated RoHS exemptions tracker (“Exemptions list – validity and rolling plan”, Dec 2025)
The European Commission published an updated RoHS exemptions tracking file (“Exemptions list – validity and rolling plan”, Dec 2025) on its official document portal. While not a legal amendment to RoHS, the tracker is operationally important for compliance teams because it consolidates exemption validity/expiry status and supports forward planning for exemption renewals, product redesigns, and evidence management tied to Annex III/IV exemptions.
European Commission publishes updated “RoHS exemptions list – validity and rolling plan” (Dec 2025)
The European Commission (DG Environment) posted an updated RoHS exemptions tracking document titled “Exemptions list – validity and rolling plan” (Dec 2025). The document consolidates RoHS Annex III/IV exemption entries along with validity and rolling-plan information, serving as an authoritative operational reference for compliance teams to monitor exemption expiry/renewal status and plan design or sourcing changes ahead of phase-outs.
ECHA December 2025 RAC/SEAC meeting highlights: PFAS restriction evaluation progressing; RAC opinion expected March 2026; SEAC draft opinion to follow
ECHA reported progress by the REACH committees (RAC and SEAC) on the proposed EU-wide PFAS restriction, indicating that RAC was expected to adopt its opinion in March 2026 and that SEAC would move toward agreeing a draft opinion for subsequent consultation. For compliance teams, this is a procedural milestone indicating when the proposal may advance to the next stage (consultation and eventual Commission decision), supporting planning for potential future PFAS restrictions across multiple sectors.
ECHA December 2025 RAC/SEAC progress update: RAC opinion expected March 2026; SEAC draft opinion to proceed to consultation
ECHA’s meeting highlights report that RAC and SEAC continued evaluating the proposed EU-wide PFAS REACH restriction. ECHA indicated RAC was expected to adopt its opinion in March 2026, and SEAC was expected to agree a draft opinion intended for stakeholder consultation. Compliance teams should treat this as an important signal on the restriction’s procedural timeline and prepare for upcoming consultation inputs and potential downstream restriction scenarios.
ECHA reports RAC/SEAC progressed EU-wide PFAS restriction evaluation; RAC opinion expected March 2026 and SEAC draft opinion to proceed to consultation
ECHA reported progress by its Committee for Risk Assessment (RAC) and Committee for Socio-Economic Analysis (SEAC) in evaluating the proposed EU-wide PFAS restriction under REACH. ECHA indicated RAC is expected to adopt its opinion in March 2026 and SEAC is expected to agree a draft opinion to be followed by a stakeholder consultation. Compliance teams should treat this as a timeline signal for when the restriction proposal could move closer to a Commission decision and begin preparing supply-chain use information and substitution planning for potentially affected PFAS uses.
EU adopts Battery Booster Strategy with €1.5B facility for battery cell producers
Commission Communication C(2025) 8950 establishes the Battery Booster Strategy to support the European battery industry. Includes €1.5 billion Battery Booster Facility from the Innovation Fund providing interest-free loans to battery cell producers during ramp-up phase. Reinforces that waste lithium-ion batteries and black mass will be classified as hazardous waste from December 2026, with exports to non-OECD countries prohibited thereafter.
UN Depositary Notification communicates amendments to Annex A listing chlorpyrifos, MCCPs, and LC‑PFCAs
A UN Depositary Notification (C.N.672.2025.TREATIES-XXVII.15) communicates the COP-12-adopted amendments to Annex A of the Stockholm Convention to list chlorpyrifos, MCCPs, and LC‑PFCAs (their salts and related compounds). For compliance teams, this notification is a key procedural milestone for the amendments’ treaty lifecycle (including objection/non-acceptance procedures and entry-into-force mechanics) and should be monitored because national/regional implementing measures may reference the notification date and resulting timelines.
European Commission publishes First CPR Working Plan 2026–2029 (COM(2025) 772) outlining rollout of harmonised specifications that will operationalise environmental sustainability declarations (EPD/EN 15804-based)
The European Commission published the First CPR Working Plan for 2026–2029 (COM(2025) 772 final). The Working Plan is an implementation roadmap under the revised Construction Products Regulation (Regulation (EU) 2024/3110) describing how harmonised technical specifications will be developed/updated and made mandatory via implementing acts. For EPD/ISO 14025/EN 15804 stakeholders, this is a key compliance-planning signal because it frames how ‘environmental sustainability characteristics’ will be integrated into construction-product documentation and declarations through the CPR acquis process and related standardisation work, which is expected to rely on EN 15804-based methods for environmental performance declaration. Compliance teams should use this to anticipate timing and prioritisation of product-family standard updates that will drive when EPD-derived data becomes required within CPR declarations for specific construction product categories.
EPA Finalizes 1,3-Butadiene Risk Evaluation under TSCA
EPA completed the final risk evaluation for 1,3-Butadiene (CAS 106-99-0) under TSCA in December 2025. The risk evaluation determines whether the chemical presents unreasonable risk to health or the environment under its conditions of use, which will inform potential risk management actions under TSCA Section 6.
ECHA Member State Committee meeting highlights: n-hexane agreed as SVHC (precursor to Candidate List inclusion)
ECHA published highlights from its Member State Committee (MSC) December meeting noting agreement to identify n-hexane as a substance of very high concern (SVHC). This is a formal step in the SVHC identification process under REACH and signals likely downstream Candidate List inclusion, which is relevant for companies to anticipate future Article 33 communication and related supply-chain compliance impacts once formally listed.
ECHA Member State Committee agrees to identify n-hexane as an SVHC (precursor to Candidate List inclusion)
ECHA reported that its Member State Committee agreed to identify n-hexane as a Substance of Very High Concern (SVHC). This committee agreement is a formal REACH SVHC process milestone that precedes Candidate List inclusion and signals that downstream obligations (e.g., article communication/notification once listed) are expected to follow when ECHA updates the Candidate List accordingly.
ECHA Decision D(2025)7771-DC (11-Dec-2025) publishes Candidate List inclusion effective 04-Feb-2026 for n-hexane and BPAF (and salts)
ECHA issued Decision D(2025)7771-DC dated 11-Dec-2025 to include substances of very high concern in the REACH Candidate List, with publication/update and decision effect stated as 04-Feb-2026. The decision supports the Candidate List update adding n-hexane (Article 57(f)) and 4,4'-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol and its salts (Article 57(c)). Compliance teams should treat the Candidate List inclusion date as the point at which article/SDS and supply-chain communication controls must reflect the updated SVHC status.
Commission publishes ‘environmental omnibus’ proposal (COM(2025) 981) to amend Battery Regulation (producer definition, labelling/substances of concern scope, and LMT battery removability/replaceability)
The European Commission issued COM(2025) 981, a proposal to amend Regulation (EU) 2023/1542. The research summary indicates the proposal would clarify the definition of “producer” (including non-established sellers regardless of sales technique), adjust the approach for removability/replaceability for LMT battery packs (module vs. cell-level), and clarify/simplify aspects of hazardous substance / substances-of-concern labelling (including reference to SVHCs). If adopted, these changes could affect producer responsibility determinations, product design/serviceability expectations for certain battery types, and compliance documentation/label content requirements.
European Commission publishes proposal COM(2025) 982 to suspend authorised representative requirement for batteries EPR (Article 56(3)) until January 2035
The European Commission published a legislative proposal (COM(2025) 982) to suspend the application of Article 56(3) of Regulation (EU) 2023/1542 (authorised representative requirement linked to extended producer responsibility for batteries) until January 2035. If adopted, the change would reduce administrative burden for certain cross-border sales scenarios by altering when/where an authorised representative must be appointed for EPR purposes. This is a proposal (not yet adopted), and should be tracked for potential downstream impacts on EPR registration strategy and representation arrangements across Member States.
European Commission publishes COM(2025) 981 proposal to amend Regulation (EU) 2023/1542 to simplify/clarify requirements (administrative burden reduction package)
The European Commission published COM(2025) 981 final (proposal) to amend Regulation (EU) 2023/1542 (and also references amendments involving Regulation (EU) 2024/1244) aiming to simplify and clarify certain requirements and reduce administrative burden. The research notes examples including clarifications to the producer definition for cross-border selling, refinements to SVHC labelling scope, adjustments related to LMT battery removability/replaceability approach, and removal of certain redundant Commission reporting. Compliance teams should monitor this proposal because it may change how obligations are interpreted or applied if adopted.
European Commission publishes proposal COM(2025) 981 to amend Battery Regulation (producer definition, hazardous substance labelling scope, LMT removability/replaceability, reporting simplification)
The European Commission published a legislative proposal (COM(2025) 981) to amend Regulation (EU) 2023/1542. The proposal would (among other changes) clarify the producer definition to cover sellers established outside a Member State irrespective of selling technique, add precision to hazardous-substance labelling scope by referencing SVHC concepts under REACH/CLP, adjust removability/replaceability expectations for LMT battery packs to module level (rather than cell level) for safety/repairability balance, and streamline certain Commission reporting obligations related to Member State waste-battery data quality. This is not yet adopted; compliance teams should track the legislative process because the amendments could change producer/EPR scoping, labelling interpretation, and design-for-removal obligations for LMT batteries.