All regulatory updates
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Stockholm Convention publishes 2025 revised text incorporating COP-12 amendments
The Stockholm Convention Secretariat published the revised text and annexes incorporating amendments adopted at COP-12 (April-May 2025). The 2025 revision includes the listing of chlorpyrifos, medium-chain chlorinated paraffins (MCCPs), and long-chain perfluorocarboxylic acids (LC-PFCAs), their salts and related compounds in Annex A. This consolidated text provides the definitive reference for current Convention obligations.
NH HB 398 requires PFAS disclosure in real estate transactions
New Hampshire HB 398 requires home sellers to notify potential buyers about the possibility of PFAS water contamination prior to executing any contract for sale of real property. Sellers must alert buyers that PFAS have been found throughout New Hampshire exceeding state and federal standards, and inform them that testing can determine if water filtration systems are needed. PFAS was added to existing mandatory disclosure requirements alongside radon, lead, and arsenic. The requirement does not apply to rental properties.
EU Environmental Footprint Transition Phase Concludes in 2025
The Environmental Footprint Transition phase, initiated in 2019, is expected to conclude in 2025. This phase aimed to monitor implementation of existing PEFCRs (Product Environmental Footprint Category Rules) and OEFSRs (Organisation Environmental Footprint Sector Rules), develop new ones, and advance methodological developments integrating latest scientific findings. After the transition phase, the EF methods are expected to enter a phase of more stability and gradually wider application. Organizations using LCA-based Environmental Footprint methods should prepare for post-transition methodological stability and broader regulatory application.
Minnesota PFAS use prohibitions take effect starting Jan 1, 2025
Minnesota’s first phase of statutory PFAS use prohibitions takes effect starting January 1, 2025 (as summarized by the Minnesota Pollution Control Agency). Compliance teams supplying into Minnesota should confirm whether any products/uses they place on the market fall into the prohibited categories effective on this date and update product stewardship, material declarations, and procurement controls accordingly.
BAT/BEP guidance for UV-328 published (January 2025)
The Secretariat published a BAT/BEP guidance document specific to UV-328 (listed under the Stockholm Convention), providing implementation-oriented recommendations to prevent/minimize exposure and releases and addressing waste/stockpile considerations. This is relevant for manufacturers and waste handlers dealing with UV-328 in articles or wastes, particularly where exemptions apply and where destruction/irreversible transformation expectations for POP wastes are discussed.
EU Battery Passport requirement takes effect February 18, 2027
The EU Battery Passport becomes mandatory for relevant battery categories placed on the EU market starting February 18, 2027. Battery manufacturers must create a Battery Passport for each battery accessible through a data carrier, containing performance, durability, safety data, supply chain information, product carbon footprint, and due diligence reports. The DPP Registry has a legal deadline of July 19, 2026. Companies must prepare data systems and supply chain traceability to meet this requirement.
UK enacts Control of Mercury Enforcement Amendment Regulations 2025
The UK enacted The Control of Mercury (Enforcement) (Amendment) Regulations 2025 (SI 2025 No. 1189), which amends enforcement provisions for mercury control regulations. This complements the substantive Control of Mercury (Amendment) Regulations 2025 and establishes the enforcement framework for Minamata Convention implementation in the UK.
Hawaii SB738 Proposes PFAS Testing for Wastewater Sludge
Senate Bill 738 would amend Hawaii Revised Statutes Chapter 342D to require wastewater treatment plants to test sewage sludge and other residual materials intended for land application for the presence of PFAS. The bill also proposes adding a definition for PFAS to the state's water pollution control statute. If enacted, this would create new monitoring and reporting obligations for wastewater facilities handling biosolids.
Massachusetts expands PFAS reporting under TURA with July 2026-2027 deadlines
Massachusetts has expanded PFAS reporting requirements under the Toxics Use Reduction Act (TURA). Seven PFAS were added to the TURA List effective January 1, 2025, with reports due to MassDEP by July 1, 2026. Nine additional PFAS were added effective January 1, 2026, with reports due by July 1, 2027. Reporting thresholds are 100 lbs for individual TRI-listed PFAS compounds and 25,000 lbs manufactured/processed or 10,000 lbs otherwise used for TURA category PFAS. The guidance establishes staggered timelines for TRI reporting, TURA tracking, and DEP reporting obligations across multiple PFAS categories.
Australia and New Zealand Release PFAS NEMP Version 3.1
Australia and New Zealand release PFAS National Environmental Management Plan (NEMP) Version 3.1, providing updated national guidance for managing per- and poly-fluoroalkyl substances (PFAS) contamination in the environment. The plan has been jointly developed by the Australian, state, territory and New Zealand governments through the National Chemicals Working Group of the Heads of EPA Australia and New Zealand, establishing a framework for consistent PFAS management across both jurisdictions.
Maryland enacts SB 901 establishing Packaging EPR program
Maryland enacted Senate Bill 901 establishing a Packaging Extended Producer Responsibility (EPR) Program. The law requires certain producers of packaging materials, individually or as part of a producer responsibility organization (PRO), to finance and manage the collection, recycling, and disposal of packaging waste. The program shifts packaging recovery costs from taxpayers to manufacturers.
EPA Issues GGRF BABA Implementation Procedures FAQs
EPA issued implementation procedures and FAQs for the Greenhouse Gas Reduction Fund (GGRF) programs under the Build America, Buy America Act. The document clarifies that BABA strengthens Made in America Laws and requires that on or after May 14, 2022, federal financial assistance for infrastructure projects must ensure all iron, steel, manufactured products, and construction materials are produced in the United States. This guidance supports GGRF recipients in meeting BABA compliance requirements.
EASA publishes 'Halon replacement in the aviation industry guide 2025' supporting EU halon-free transition (incl. Annex V deadlines and derogations context)
EASA made available the 'Halon replacement in the aviation industry guide 2025' to support implementation of Regulation (EU) 2024/590 in the aviation sector. The guide compiles Annex V deadline information (including the 31 Dec 2025 end date for portable extinguishers protecting cabins and crew compartments) and explains compliance pathways and the derogations process (via Member State competent authority requests to the European Commission). Compliance teams can use this guidance to validate aircraft configuration changes, technical acceptance criteria, and regulatory interaction steps for any exceptional cases.
Vermont Act 54 revises PFAS product ban framework with phased effective dates
Vermont Act 54 (2025) revises the PFAS product ban framework established in Act 131 (2024). The act restructures the statute for regulation of PFAS in consumer products, extends the cookware PFAS sales prohibition effective date to July 1, 2028, and establishes a prohibition on fluorine treated containers effective January 1, 2032. Products including cosmetics, menstrual products, certain consumer products, food packaging, and firefighting equipment are subject to PFAS restrictions effective January 1, 2026. The Secretary of Natural Resources must submit a report to the General Assembly by January 15, 2027.
Commission opens infringement against Cyprus for RoHS transposition failure
The European Commission opened infringement procedures against Cyprus by sending a letter of formal notice for failing to transpose into national legislation Commission Delegated Directive (EU) 2024/1416, which amends the RoHS Directive (2011/65/EU) regarding an exemption for cadmium in downshifting quantum dots directly deposited on LED semiconductor chips. Member States are required to transpose delegated directives within specified timeframes; non-compliance triggers enforcement action. This signals the Commission's active monitoring of RoHS transposition across Member States.
Clean Truck Check compliance fee increases to $32.13 effective January 1, 2026
CARB updated the Clean Truck Check compliance fee to $32.13, reflecting a CPI adjustment, effective January 1, 2026. The fee applies to almost all non-gasoline heavy-duty vehicles with a gross vehicle weight rating greater than 14,000 pounds operating in California. This replaces the previous fee of $31.18.
AB 1817 Textile PFAS Threshold Drops to 50 ppm on January 1, 2027
California AB 1817 establishes a phased compliance threshold for PFAS in textile articles. The initial 100 ppm total organic fluorine threshold, in effect since January 1, 2025, will tighten to 50 ppm on January 1, 2027. Textile manufacturers and distributors must ensure products meet the lower threshold by the compliance date. 'Regulated PFAS' includes both intentionally added PFAS and PFAS present above the threshold as measured in total organic fluorine.
European Commission RoHS implementation page reiterates exemption renewal validity and transition rules (official procedural guidance)
The European Commission’s RoHS Directive implementation page provides authoritative procedural guidance on exemption renewals under Directive 2011/65/EU. It explains that timely renewal requests keep exemptions valid until a Commission decision is taken, and that rejected renewals typically include a 12–18 month transition period before expiry. It also notes expected decision timelines and links to the exemptions list and exemption application guidance materials. Compliance teams should use this page to plan exemption renewal submissions (18 months before expiry) and manage transition planning when exemptions are rejected or revised.
2025 consolidated text of the Stockholm Convention (updated compilation) published
An updated consolidated compilation of the Stockholm Convention text and annexes (2025 version) is available as an official PDF. While this is not itself a new listing decision, it is compliance-relevant as a current reference of the treaty text incorporating adopted amendments up to the compilation date.
NY PFAS apparel ban in effect; outdoor apparel ban effective 2028
New York's prohibition on apparel containing intentionally added PFAS took effect January 1, 2025. NYSDEC must establish PFAS threshold levels in apparel by regulation by January 1, 2027. A separate ban on outdoor apparel for severe wet conditions containing PFAS takes effect January 1, 2028. The law covers stain resistance, water and oil repellency applications of PFAS in textile products.