All regulatory updates

India Adds Solar Panels and Medical Devices to E-Waste Schedule II

The E-Waste (Management) Amendment Rules, 2023 (G.S.R. 61(E)) add two new items to Schedule II of the E-Waste (Management) Rules, 2022. Item 36 covers cadmium and lead in solar panels, cells, and photovoltaic modules. Item 37 covers lead in medical devices, excluding implanted and infected products. The amendment also modifies Rule 16(5), replacing the requirement for information in product user documentation with submission 'as and when required by the Central Pollution Control Board.' Producers, manufacturers, and importers of solar equipment and medical devices must now comply with EPR obligations for these product categories. Effective April 1, 2023.

MoEFCC notifies E-Waste (Management) Rules, 2022 (principal rules text published)

MoEFCC published the E-Waste (Management) Rules, 2022 in the Gazette of India (official PDF). The rules establish the binding EPR-based compliance framework for e-waste in India, including CPCB portal registration for obligated entities (e.g., producers, recyclers, refurbishers), and required returns/reporting mechanisms as set out in the rules. The PDF indicates the rules take effect from 1 April 2023, which is the core go-live date for compliance obligations under this framework.

NY DOH Proposes PFAS Drinking Water Regulations for 23 Emerging Contaminants

The New York State Department of Health announced proposed regulations for PFAS in drinking water systems, establishing Maximum Contaminant Levels (MCLs) for 23 additional emerging contaminants. The proposed regulations are amendments to Public Health Law signed by Governor Kathy Hochul and represent the Department's effort to address emerging contaminants including per- and polyfluoroalkyl substances (PFAS). PFAS break down slowly in the environment and have contaminated drinking water supplies leading to exposure and health concerns.

California enacts AB 1817 banning PFAS in textile articles

California AB 1817 (Safer Clothes and Textiles Act) prohibits manufacturing, distributing, selling, or offering for sale any new textile articles containing regulated PFAS. The regulation establishes a threshold of 100 ppm total organic fluorine starting January 1, 2025, tightening to 50 ppm from January 1, 2027. Manufacturers must provide certificates of compliance and use the least toxic alternatives when replacing PFAS. The law covers apparel, outdoor apparel, and related textile products.

California AB 1817 Requires PFAS Disclosure for Outdoor Apparel for Severe Wet Conditions

AB 1817 requires that, starting January 1, 2025, any outdoor apparel for severe wet conditions (such as offshore fishing, sailing, whitewater kayaking, and mountaineering gear) containing regulated PFAS must be accompanied by a legible disclosure stating 'Made with PFAS chemicals.' This disclosure requirement applies until the full prohibition takes effect on January 1, 2028. The requirement includes online listings of products for sale.

California AB 1817 Requires Certificate of Compliance for Textile Articles

AB 1817 requires manufacturers of textile articles to provide persons offering the product for sale or distribution in California with a certificate of compliance stating that the textile article does not contain regulated PFAS. The certificate must be signed by an authorized official of the manufacturer and may be provided electronically. Distributors and retailers who rely in good faith on the certificate are not liable for violations.

California AB 1200 Bans PFAS in Plant-Based Food Packaging

California AB 1200 prohibits the distribution, sale, or offering for sale of plant-based food packaging containing intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS). The regulation defines PFAS as fluorinated organic chemicals containing at least one fully fluorinated carbon atom, and establishes a threshold of 100 parts per million for PFAS presence in products. The ban applies to food packaging made from plant fibers, paper, or other plant-derived materials. This restriction is distinct from California's other PFAS product laws including AB 652 (juvenile products), AB 2771 (cosmetics), AB 1817 (textile articles), and AB 2515 (menstrual products).

California enacts AB 2771 banning intentionally added PFAS in cosmetic products

California AB 2771 prohibits manufacturing, selling, delivering, holding, or offering for sale any cosmetic product containing intentionally added PFAS, effective January 1, 2025. The law defines 'intentionally added PFAS' as PFAS that a manufacturer has intentionally added to a product with a functional or technical effect, including PFAS that are intentional breakdown products of an added chemical. Manufacturers must ensure cosmetic products placed on the California market are free of intentionally added PFAS and provide certificates of compliance.

California AB 1200 Requires Cookware Chemical Disclosure for Designated List Chemicals

California AB 1200 (Article 2) requires manufacturers of cookware sold in California containing chemicals from DTSC's designated list in handles or food-contact surfaces to disclose this information. Effective January 1, 2023, manufacturers must post on their website a list of all designated list chemicals in the cookware with links to authoritative lists. Effective January 1, 2024, product labels must display this information with a website address and QR code. Manufacturers are prohibited from making 'free of X' claims for any chemical group on the designated list unless the product is free of all chemicals in that group. Cookware includes pots, pans, skillets, grills, baking sheets, molds, trays, bowls, and cooking utensils.

California AB 2771 Bans Intentionally Added PFAS in Cosmetics

California AB 2771 (PFAS-Free Beauty Act of 2022) prohibits, beginning January 1, 2025, any person or entity from manufacturing or offering for sale in commerce any cosmetic product that contains intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS). The ban applies to all cosmetic products and personal care products sold in California. Manufacturers, importers, and retailers must ensure cosmetic products do not contain intentionally added PFAS by the effective date.

Rhode Island PFAS Act establishes 20 ppt drinking water standard for six PFAS

The Rhode Island PFAS in Drinking Water, Groundwater, and Surface Waters Act (R.I. Gen. Laws § 46-32-1 et seq.) was passed in 2022 and amended in 2023. The Act requires public water systems to monitor for six specific PFAS substances (PFOA, PFOS, PFHxS, PFNA, PFHpA, and PFDA) with an interim state standard of 20 parts per trillion (ppt) total for the six PFAS. Public water systems were required to complete initial sampling by July 1, 2023. Systems exceeding the interim standard entered into Consent Agreements with the Rhode Island Department of Health (RIDOH) and must take action to reduce PFAS levels. Regular ongoing testing is required for all public water systems in Rhode Island.

Nevada PFAS Action Plan establishes statewide remediation framework

Nevada's Final PFAS Action Plan establishes a comprehensive framework for addressing PFAS contamination statewide. Enacted under Assembly Bill 97, the plan created a PFAS Working Group to study environmental contamination issues. Nevada has enacted PFAS-related statutes (NRS 459.682 and 459.684) prohibiting PFAS-containing Class B firefighting foam use for testing/training since January 1, 2022, with mandatory 24-hour notification requirements for any discharge. The action plan addresses monitoring, remediation, and regulatory coordination for PFAS contamination in Nevada's water supplies.

Recent updates under the Build America, Buy America Act (BABAA) have introduced additional compliance and reporting requirements for federally funded infrastructure projects in the United States. The newly introduced Build America, Buy America Compliance Act (S. 4393) requires federal agencies to report BABA implementation status, compliance actions, and waiver usage annually. The measures apply to products containing iron, steel, manufactured products, and construction materials used in infrastructure projects. Products may still be considered non-compliant if BABAA domestic sourcing requirements are not fully satisfied.

PFOA and PFOS Listed Under Proposition 65 for Reproductive Toxicity

Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonate (PFOS) were listed effective November 10, 2017, as known to the State of California to cause reproductive toxicity (developmental endpoint) under the authoritative bodies mechanism (US EPA). Manufacturers, importers, and distributors of products containing PFOA or PFOS above significant exposure levels must provide Proposition 65 warnings. PFOA was subsequently listed for cancer (effective February 25, 2022) and PFOS was listed for cancer (effective December 24, 2021), expanding warning requirements for these PFAS chemicals.

RMI hosts CMRT Completion Guide document (legacy guide corresponding to CMRT Revision 5.0)

An RMI-hosted CMRT guide PDF is available on the official domain and provides completion guidance (including handling duplicates and smelter location distinctions). The research indicates this is a legacy guide (corresponding to CMRT Revision 5.0, released May 12, 2017) rather than a newly issued guide within the last ~30 days; however, it remains an authoritative reference for CMRT completion practices where still applicable.

RMI publishes CMRT Completion Guide (corresponding to CMRT Revision 5.0, released May 12, 2017)

RMI makes available a CMRT Completion Guide PDF that provides instructions/definitions and completion guidance for the CMRT (the guide explicitly corresponds to CMRT Revision 5.0 and notes the related CMRT release date of May 12, 2017). While not a recent update, this is authoritative guidance used by compliance teams to correctly complete CMRT fields and avoid validation/format errors in supplier responses.

RMI FAQ clarifies CMRT April releases generally do not require re-surveying suppliers for the upcoming filing year

RMI guidance (Downstream FAQ) explains that CMRT updates are typically released in April and are intended for use in the next year’s filing cycle. The FAQ advises companies to use the most recent CMRT version when launching their annual supplier survey, document which CMRT version they accepted, and indicates companies generally do not need to re-survey suppliers solely because a new CMRT version is released in April for the upcoming filing. Compliance teams can use this guidance to set internal survey timing, version-control practices, and supplier outreach policies around CMRT annual updates.

RMI CMRT template access/download page is gated behind Terms & Conditions (limits automated retrieval of current CMRT version)

The official RMI CMRT template page requires acceptance of Terms & Conditions before the CMRT file can be accessed/downloaded, and the publicly viewable content does not expose the current CMRT version or release notes without passing the gate. This is operationally relevant for compliance teams because it can affect automated template distribution, internal controls over which CMRT version is used in supplier surveys, and evidence collection for version traceability (e.g., documenting when/where the CMRT was obtained).

On 4 February 2026, the European Commission proposed listing bis(2-ethylhexyl) tetrabromophthalate (TBPH) (CAS No. 26040-51-7 and EC No. 247-426-5.) as a Persistent Organic Pollutant under the European Commission framework. TBPH is a persistent, bioaccumulative, and toxic brominated flame retardant, and this nomination is the first step toward a global phase-out aligned with the Stockholm Convention on Persistent Organic Pollutants.

On 4 February 2026, the European Commission officially proposed the listing of bis(2-ethylhexyl) tetrabromophthalate (TBPH) as a Persistent Organic Pollutant (POP). TBPH is a brominated flame retardant (BFR) that has been identified as highly persistent, bioaccumulative, and toxic (PBT). It is also capable of long-range environmental transport, having been detected in remote Arctic regions. The EU's nomination is the first step in a global phase-out process. By nominating TBPH now, the EU aims to align its internal REACH restrictions with international law to prevent "regulatory leakage" from non-EU imports