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Exemption UpdateLiveSep 30, 2024

FHWA approves project-specific BABA waiver for IDOT Pump Station 37

FHWA published a Buy America waiver notification for the Illinois Department of Transportation's (IDOT) Pump Station 37 Project. The waiver is limited to applicable purchases by IDOT, IDOT's contractors, or subcontractors of the waiver items (submersible pumps). The waiver does not apply to purchases made for any other products or projects. The waiver is effective from the effective date of the final waiver through the period of performance and closeout of FHWA's financial assistance for the project, estimated to be October 2028.

Build America, Buy America Act (BABA)Federal Highway Administration (FHWA)Sep 30, 2024
Regulation ChangeLiveSep 30, 2024

California enacts AB 2515 banning PFAS in menstrual products

AB 2515 (Chapter 1008, Statutes of 2024) prohibits the manufacture, sale, delivery, holding, or offering for sale in California of menstrual products containing intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS). Expands California's comprehensive PFAS product restrictions beyond existing categories (textiles, cosmetics, juvenile products, food packaging).

PFAS CaliforniaCalifornia LegislatureSep 30, 2024
Regulation ChangeLiveSep 29, 2024

California enacts AB 347 establishing PFAS enforcement framework

AB 347 (Chapter 932, Statutes of 2024) creates California's first comprehensive enforcement mechanism for PFAS product prohibitions under AB 1817 (textiles), AB 1200 (food packaging), and AB 652 (juvenile products). DTSC must adopt regulations and publish testing methods by January 1, 2029. Manufacturers must register and provide compliance statements by July 1, 2029. Enforcement with penalty authority begins July 1, 2030.

PFAS CaliforniaCalifornia LegislatureSep 29, 2024
Enforcement ActionLiveSep 26, 2024

Commission opens infringement procedures against Portugal and Slovakia for failure to transpose RoHS Delegated Directive (EU) 2024/232 (recovered rigid PVC profiles exemption conditions)

The European Commission opened infringement procedures (letters of formal notice) against Portugal and Slovakia for failure to communicate national transposition measures for Commission Delegated Directive (EU) 2024/232 by the required deadline stated in the research text (31 July 2024). The delegated directive amends RoHS to enable certain uses of recovered rigid PVC in plastic profiles for electrical/electronic windows and doors under specified conditions (including cadmium and lead concentration limits and marking/traceability requirements as described in the research text). This enforcement action is relevant for companies relying on Member State implementation of the exemption and indicates increased Commission scrutiny on timely transposition of RoHS delegated directives.

EU RoHS (Directive 2011/65/EU)European CommissionSep 26, 2024
Enforcement ActionLiveSep 26, 2024

European Commission infringement action for failure to transpose Delegated Directive (EU) 2024/232 (exemption for cadmium/lead in recovered rigid PVC profiles)

The European Commission adopted an infringements package that includes letters of formal notice to Portugal and Slovakia for failing to transpose Commission Delegated Directive (EU) 2024/232 amending Directive 2011/65/EU (RoHS). The delegated directive introduces a RoHS exemption for certain applications involving cadmium and lead in plastic profiles in electrical and electronic windows and doors containing recovered rigid PVC. Compliance teams placing such products on the EU market should monitor national transposition/implementation in the cited Member States, as lack of transposition can create market-access uncertainty for products relying on the exemption despite EU-level adoption.

EU RoHS (Directive 2011/65/EU)European CommissionSep 26, 2024
Reporting RequirementProposedSep 12, 2024

RMI announces upcoming EMRT 2.0 (planned April 2025) with scope expansion to copper, natural graphite, lithium, and nickel and an optional mine-level facility tab

RMI announced its plan to release EMRT 2.0 in April 2025, expanding EMRT mineral scope to include copper, natural graphite, lithium, and nickel (in addition to the pre-existing EMRT minerals), and introducing an optional mine-level facility tab. For organizations that use EMRT to meet downstream customer due diligence expectations, this signals expanded supplier data needs and potential system/template changes ahead of the planned release.

EMRT (Extended Minerals Reporting Template)Responsible Minerals Initiative (RMI)Sep 12, 2024
Reporting RequirementProposedSep 12, 2024

RMI announces upcoming EMRT 2.0 release and expands EMRT mineral scope to copper, natural graphite, lithium, and nickel

RMI published an official announcement that the next major EMRT release (EMRT 2.0) is planned for April 2025 and will expand EMRT reporting scope by adding four minerals: copper, natural graphite, lithium, and nickel (in addition to existing EMRT minerals). This is directly relevant to EMRT users because supplier surveys, internal scoping logic, and downstream customer requirements must be updated to collect and validate sourcing/processor information for the expanded mineral set once EMRT 2.0 is adopted.

EMRT (Extended Minerals Reporting Template)Responsible Minerals Initiative (RMI)Sep 12, 2024
Substance AdditionProposedSep 12, 2024

RMI announces upcoming EMRT 2.0 scope expansion to add copper, natural graphite, lithium, and nickel

RMI announced that the upcoming EMRT 2.0 release would expand the EMRT reporting scope by adding four minerals—copper, natural graphite, lithium, and nickel—alongside existing EMRT minerals (cobalt and mica). This scope expansion is relevant for compliance teams because it increases supplier data-collection requirements and due-diligence coverage for energy-transition and battery-related minerals.

EMRT (Extended Minerals Reporting Template)Responsible Minerals Initiative (RMI)Sep 12, 2024
Regulation ChangeLiveJul 30, 2024

Revised EU Mercury Regulation enters into force (dental amalgam and mercury lamp restrictions; temporary derogation until 30 June 2026)

The European Commission announced that the revised EU Mercury Regulation entered into force, strengthening mercury phase-out measures. Key compliance impacts highlighted include restrictions affecting dental amalgam (including a prohibition on use and export by 1 January 2025, with a temporary derogation for certain Member States until 30 June 2026) and restrictions on certain mercury-containing lamp categories with phase-out dates (depending on lamp category). This matters for compliance teams because product portfolios (especially dental and lighting products) may require redesign/substitution, supply-chain changes, and country-by-country planning to account for transition arrangements and derogation timelines.

EU Mercury Regulation (Regulation (EU) 2017/852), amended by Regulation (EU) 2024/1849European CommissionJul 30, 2024
Regulation ChangeLiveJul 30, 2024

EU revised mercury rules entered into force (Regulation (EU) 2024/1849), including dental amalgam phase-out/export ban and lamp phase-out deadlines (incl. 30 June 2026 derogation end)

The European Commission’s mercury policy page points to the revised EU mercury framework, noting that Regulation (EU) 2024/1849 entered into force on 30 July 2024. The page summarizes key mercury-free transition measures including: (1) dental amalgam phase-out and export ban by 1 January 2025, with a temporary derogation available until 30 June 2026 for Member States needing more time; and (2) phase-outs for additional mercury-containing lamps with manufacture/export bans beginning 31 December 2025 or 31 December 2026 depending on lamp type. Compliance teams should validate product portfolios (dental and lighting sectors in particular), confirm Member State derogation status where relevant, and manage end-of-sale/export planning and substantiation for any allowed exceptions.

Regulation (EU) 2017/852 on mercury (as amended by Regulation (EU) 2024/1849)European CommissionJul 30, 2024
Regulation ChangeLiveJul 30, 2024

Revised EU Mercury Regulation enters into force (updates mercury-free transition measures, including dental amalgam and mercury-containing lamps; includes time-limited derogations)

The European Commission announced that the revised EU Mercury Regulation entered into force, strengthening mercury controls to support a mercury-free environment. The update is described as phasing out remaining intentional uses (including dental amalgam and mercury-containing lamps) and includes time-limited derogations, including a derogation referenced as running until 2026-06-30 for some Member States concerning dental amalgam. Compliance teams placing relevant products on the EU market (e.g., dental sector and lighting) should evaluate the updated prohibitions/derogations and associated timelines for product design, sourcing, and market access.

EU Mercury Regulation (Regulation (EU) 2017/852)European CommissionJul 30, 2024
Regulation ChangeLiveJun 28, 2024

ESPR Regulation (EU) 2024/1781 published as in-force legal framework enabling Digital Product Passport via delegated acts

Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR) is identified as the core in-force legal framework for Digital Product Passports (DPP), with DPP obligations becoming concrete through subsequent product-specific delegated acts. This establishes the binding framework basis for DPP-related compliance planning across product categories covered under ESPR implementation.

EU Digital Product Passport (DPP) / ESPR frameworkEuropean Union (legislator)Jun 28, 2024
Regulation ChangeLiveJun 28, 2024

Regulation (EU) 2024/1781 (ESPR) published on EUR-Lex as the in-force framework regulation

EUR-Lex publication of Regulation (EU) 2024/1781, the core legal act establishing the EU Ecodesign for Sustainable Products Regulation (ESPR) framework. This is the binding baseline for subsequent delegated/implementing acts (e.g., product-group ecodesign requirements, Digital Product Passport rules, and rules on destruction/disclosure for unsold consumer products). Compliance teams should use this as the authoritative legal anchor when mapping ESPR obligations and tracking future implementing measures.

EU Ecodesign for Sustainable Products Regulation (ESPR)European Parliament and the Council of the European UnionJun 28, 2024
Regulation ChangeLiveJun 19, 2024

Canada amends Products Containing Mercury Regulations via SOR/2024-109 (new prohibitions/labeling/contravention handling; revised reporting cadence incl. 2025 report due Mar 31, 2026; in force June 19, 2025)

Canada published SOR/2024-109 amending the Products Containing Mercury Regulations under CEPA. Per the research text, the amendments come into force on the first anniversary of publication in Canada Gazette Part II (publication 2024-06-19; in force 2025-06-19). The amendments update the prohibitions/exemptions framework and introduce/clarify compliance mechanics, including: (1) revised reporting cadence and deadlines—calendar year 2025 report due 2026-03-31; calendar year 2027 report due 2028-03-31; then every third year; (2) new/explicit export quantity reporting elements; (3) labeling updates (including identifying mercury-containing components and allowing certain information via website reference under conditions); and (4) obligations for products manufactured/imported in contravention to be directed to authorized final disposal/recycling (or returned to sender for imports). Compliance teams should update product eligibility assessments, labeling/artwork, recordkeeping, and reporting workflows to meet the amended requirements and cadence.

Canada — Products Containing Mercury Regulations (SOR/2014-254)Environment and Climate Change Canada (ECCC)Jun 19, 2024
Reporting RequirementLiveMay 1, 2024

GSA issues revised BABA Waiver Request Form OF 2211

GSA issued Optional Form 2211 (Revision 5/2024), the Build America Buy America Waiver Request Data Collection form. This standardized form is used for submitting waiver requests to BABA requirements. The form collects information necessary for agencies to evaluate waiver requests for domestic sourcing requirements under Section 70914 of BABA. Form expires 09/30/2026 under OMB Control No. 0505-0028.

Build America, Buy America Act (BABA)U.S. General Services Administration (GSA)May 1, 2024
Regulation ChangeLiveMar 8, 2024

MoEFCC notifies E-Waste (Management) Amendment Rules, 8 March 2024 (return timeline relaxation + EPR certificate platform pricing bounds)

MoEFCC notified the E-Waste (Management) Amendment Rules dated 8 March 2024 amending the E-Waste (Management) Rules, 2022. Key compliance impacts captured in the official PDF include: (1) Rule 3 definition update for “dismantler” aligning the definition to dismantling in accordance with CPCB guidelines; (2) insertion of new Rule 9A allowing the Central Government to relax timelines for filing required returns/reports for a further period not exceeding nine months (in public interest/effective implementation), which affects compliance calendar and potential late-filing exposure; and (3) amendments to Rule 15 enabling establishment of one or more platforms for exchange/transfer of EPR certificates per CPCB guidelines and Central Government approval, and requiring CPCB to set a price band for EPR certificate exchange—highest at 100% and lowest at 30% of the environmental compensation for non-fulfilment under Rule 22—constraining permissible transaction prices between registered entities and shaping EPR credit procurement strategies.

India E-Waste (Management) Rules, 2022Ministry of Environment, Forest and Climate Change (MoEFCC)Mar 8, 2024
Regulation ChangeLiveJan 1, 2024

ISO publishes ISO 14072:2024 standard for organizational life cycle assessment aligned to ISO 14040/14044

ISO has published ISO 14072:2024 (Environmental management — Life cycle assessment — Requirements and guidance for organizational life cycle assessment). The standard provides requirements and guidance for applying ISO 14040/14044 principles at the organization level (organizational LCA). Compliance teams using ISO 14040/14044 as a required LCA framework (e.g., via customer, procurement, or program rules) should assess whether internal LCA procedures, data collection, and reporting expectations need to be updated to align with ISO 14072:2024 (noting it replaces ISO/TS 14072:2014).

Life Cycle Assessment (ISO 14040/14044)International Organization for Standardization (ISO)Jan 1, 2024
Guidance UpdateLiveJan 1, 2024

ISO publishes ISO 14072:2024 organizational LCA standard (requirements and guidance applying ISO 14040/14044 at the organization level)

ISO published ISO 14072:2024, which specifies additional requirements and provides guidance for applying ISO 14040:2006 and ISO 14044:2006 to organizations (organizational life cycle assessment). This is relevant to LCA programs using ISO 14040/14044 as the methodological foundation and needing a standardized approach for organizational-level assessments. The ISO standard page indicates this is a successor to ISO/TS 14072:2014 (transition from Technical Specification to International Standard). No specific regulatory enforcement date or legal mandate is indicated in the provided source.

Life Cycle Assessment (ISO 14040/14044)International Organization for Standardization (ISO)Jan 1, 2024
Substance AdditionLiveDec 19, 2023

ECHA decision to publish and update the Candidate List on 23 Jan 2024 (incl. new SVHC inclusions and update to dibutyl phthalate entry)

ECHA Decision D(2023)8585-DC (signed 19 Dec 2023) states ECHA will publish and update the REACH Candidate List of SVHCs on 23 Jan 2024. The decision identifies multiple substances to be included on that date (e.g., 2,4,6-tri-tert-butylphenol; Bumetrizole; oligomerisation and alkylation reaction products of 2-phenylpropene and phenol; and 2-(2H-benzotriazol-2-yl)-4-(1,1,3,3-tetramethylbutyl)phenol), and also updates the existing Candidate List entry for dibutyl phthalate to reflect additional intrinsic properties of concern. Compliance teams should ensure SVHC screening lists and article-level communication/notification processes reflect the updated Candidate List as of 23 Jan 2024 and capture the updated hazard basis for dibutyl phthalate where it affects internal declarations and customer communications.

REACH SVHCEuropean Chemicals Agency (ECHA)Dec 19, 2023
Public CommentProposedDec 7, 2023

European Commission proposes amending RoHS to re-attribute scientific and technical tasks to ECHA ("one substance, one assessment")

The European Commission published a legislative proposal (COM(2023) 781) to amend Directive 2011/65/EU (RoHS) to re-attribute scientific and technical tasks (notably supporting processes under Article 5 exemptions and Article 6 review/amendment of restricted substances) to the European Chemicals Agency (ECHA). If adopted, this would change how RoHS exemptions and potential restriction updates are scientifically assessed and managed, with implications for exemption application strategy, evidence requirements, and monitoring of RoHS restriction/exemption decision-making workflows.

EU RoHS (Directive 2011/65/EU)European CommissionDec 7, 2023