Regulatory News - Summer 2026
1. Great Britain started running its own clock
The REACH (Amendment) (No. 2) Regulations 2026 were made on 16 July as SI 2026 No. 849 and came into force on 6 August, moving the three UK REACH transitional registration deadlines from 27 October 2026, 2028 and 2030 to 27 October 2029, 2030 and 2031. The Article 41(5) compliance-check milestones shift correspondingly to 2030, 2032 and 2036. Defra’s stated reason is that the Alternative Transitional Registration model cannot be delivered in time for the original first deadline.
Now, three years is a generous reprieve. It is also probably the softest change in GB compliance this summer.
Everything else moved the other way. On 15 June, HSE added 15 SVHCs to the UK REACH Candidate List, taking it to 224 entries. This is the first substantive update since the list was inherited at Brexit, but all 15 were already on the EU Candidate List, so this is more of a catch-up rather than divergence. However, the duties this creates are new, and they run on GB dates. A consultation on nine more closed on 20 August, among them medium-chain chlorinated paraffins, perfluoroheptanoic acid and bisphenol AF.
On classification, we can see the actual divergence. The sixth edition of the GB Mandatory Classification and Labelling list became binding on 15 August for 46 substances, including nonylphenol ethoxylates, hydrogen sulfide and diuron. Stock released into the GB supply chain after that date carrying superseded classifications is non-compliant. On 7 August, HSE notified the WTO of 20 further MCL entries. Among them bisphenol F, bronopol, tebuconazole, tea tree oil, eugenol, 2-pyrrolidone, ulexite, natural borax and thymol. The comment period closes on 6 October 2026, with adoption expected in the first quarter of 2027 and mandatory application from the third quarter of 2028.
The registration deadline may have moved, but the classification obligations did not. A GB portfolio that was compliant in May is not necessarily compliant now, and the extension does nothing about that. It also does not justify pausing data-access negotiations as the ATRm technical requirements have not yet been defined, although Defra has now set out its intended streamlined approach and said that the final requirements will not exceed the 2024 consultation proposals.
What not to miss
- Reconcile your GB portfolio against the sixth-edition MCL list and reissue affected safety data sheets and labels. That deadline was 15 August, not a future one.
- Screen GB articles against the 15 substances listed in June, and monitor the outcome for the nine consulted on. Where a listed substance exceeds 0.1 % w/w, assess the supply-chain communication duties, and evaluate notification separately against the tonnage threshold and available exemptions.
Sources: legislation.gov.uk — SI 2026/849 · HSE — GB MCL list
2. Deadlines, deadlines everywhere
The summer’s compliance calendar was front-loaded. The 22nd ATP to CLP, Regulation (EU) 2024/2564, became mandatory on 1 May, adding 27 new harmonised classifications to Annex VI, amending 16 entries and deleting seven. The first emission report under the microplastics restriction fell due on 31 May, covering 2025 losses of pellets, flakes and powders at manufacturers and industrial users of plastic feedstock. On 1 July the headline provisions of the 2024 CLP revision came into application, including the Article 61(7) label exemptions, with stock already in the supply chain running to 1 July 2028.
Two later dates deserve attention, too. On 6 August, the formaldehyde emission limits for articles under REACH Annex XVII Entry 77 became applicable, introduced by Regulation (EU) 2023/1464. Furniture and wood-based articles are capped at 0.062 mg/m³ under the test conditions specified in Appendix 14 and other indoor articles at 0.080 mg/m³; vehicle interiors follow on 6 August 2027. It passed almost without trade coverage, and it bears directly on wood-based panels, furniture and automotive interiors. Two days earlier, on 4 August, the six-month Article 7(2) notification period ended for n-hexane and bisphenol AF. It applies where articles contain the substance above 0.1 % w/w and the total quantity across those articles exceeds one tonne a year.
Also worth returning to: C&L notifier names. Under Article 42 of the CLP Regulation as amended by Regulation (EU) 2024/2865, the confidentiality window closed on 30 June and ECHA began publishing notifier names in ECHA CHEM on 1 July. Companies that justified a commercial-harm claim before the deadline are excluded, and for group notifications only the lead notifier appears. For active notifications, the classifications recorded against a substance can now be linked publicly to the notifier. A divergent classification for the same substance is now a matter of public record, attached to a company name. Whether that reads as risk or opportunity depends entirely on what your entries say.
What not to miss
- Look up what ECHA CHEM now shows against your notifier name, and confirm the disclosure was intended. This is the item most likely to have gone unchecked over the holidays.
- Confirm compliance evidence under Entry 77 and its Appendix 14 for in-scope articles placed on the EU market since 6 August. Vehicle interiors have until 6 August 2027.
- If an Article 7(2) notification for n-hexane or bisphenol AF was missed on 4 August, file it. The obligation stands independently of the deadline.
????We hold regular free Q&A webinars on Zoom. Join the next one on 16 September at 10 AM CEST. We will focus on Biocides, CLP Changes, C&L Inventory, Labelling. Past editions can be found on our YouTube.
Sources: EUR-Lex — Regulation (EU) 2023/1464 (formaldehyde) · EUR-Lex — 22nd ATP to CLP · ECHA — notifier names in the C&L Inventory
3. All around PFAS: the little definition that could
The universal PFAS restriction is probably the slowest-moving part of PFAS regulation. The last structured opportunity to influence the assessment – the SEAC consultation – closed on 25 May. SEAC’s final opinion is expected around the end of 2026, after which the Commission drafts the Annex XVII amendment, a process running into 2027 and probably beyond.
Everything around it moved faster.
On 12 August, the Packaging and Packaging Waste Regulation became generally applicable, and with it the Article 5(5) PFAS limits for food-contact packaging: 25 ppb for any single PFAS, 250 ppb for the sum, and 50 ppm for total PFAS including polymeric. The limits attach to placing on the market, not to manufacture. Packaging already on the market before 12 August may stay in circulation, but an earlier manufacturing date is not a sell-through exemption for anything first placed on the market after it. There is no harmonised test method. Commission guidance recommends total fluorine screening as a first step: a result below 50 mg/kg may be taken as an indication of compliance, while anything above it requires evidence separating PFAS-derived fluorine from other sources.
That combination – a workable PFAS definition, numeric limits, and total fluorine as the practical proxy – is now being copied. Sweden’s July consultation on a national PFAS ban covering clothing, footwear, impregnating agents, cosmetics, the food-contact parts of kitchenware and ski wax takes its definition from Article 5(5) PPWR and its limits from the same place, including the presumption that fluorine above 50 mg/kg originates from PFAS unless the supplier demonstrates otherwise.
~PPWR intermission~
The PPWR perimeter is also widening beyond PFAS. The same regulation sets a general limit of 100 mg/kg for combined lead, cadmium, mercury and hexavalent chromium in packaging, subject to exemptions and derogations. In July ECHA opened consultation on a draft list of substances of concern in packaging (roughly 700 entries spanning plastics, paper, metal, glass and ceramics, screened against the ESPR criteria) with comments closing on 24 August and the final report due to the Commission by 21 September. Packaging is becoming a chemicals file in its own right.
One PPWR obligation is still being built while the regulation is already in force. On 6 August, the Commission published its draft implementing act setting the harmonised format for national producer registers under Article 44 — nearly six months after the February 2026 statutory deadline for it passed. Feedback closes at midnight Brussels time on 10 September 2026. Anyone managing registration across several Member States has a narrow window to influence whether those registers converge or fragment on EU commission feedback page.
The issue is increasingly resonating with micro-enterprises, sole traders, independent creators and small online shops selling across borders. Under Article 45(3), a producer selling packaged products directly to end users in another Member State must appoint, by written mandate, an authorised representative for extended producer responsibility in each such Member State other than the one where it is established. In practice, a one-person business selling directly to consumers across several EU countries may therefore face separate producer registrations, EPR arrangements and local representation in multiple jurisdictions, even where the quantities of packaging involved are very small. For a business with one employee, the administrative footprint may therefore depend more on the number of Member States served than on the amount of packaging placed on the market.
PPWR contains some targeted exemptions and derogations for micro-enterprises, but it does not create a blanket small-business exemption from these cross-border EPR obligations. This means that many one-person and micro-businesses still need to determine whether they qualify as a producer, which national obligations apply and whether any specific exemption is available. For sellers using online marketplaces, the practical pressure is likely to be even more visible, as platforms must obtain producer registration information and confirmation of EPR compliance before allowing producers to sell to consumers in the Union.
The burden has already been recognised at EU level. In December 2025, the Commission proposed suspending the Article 45(3) requirement to appoint an authorised representative for EPR until 1 January 2035, explicitly as a measure to reduce administrative burdens and costs, particularly for businesses operating across borders. The proposal has not yet been adopted: as of September 2026, the ordinary legislative procedure is still ongoing and the European Parliament is awaiting a committee decision. Until the amendment is adopted and enters into force, however, the existing PPWR requirement remains the applicable legal rule.
~End of PPWR intermission~
And in June, ECHA’s Risk Assessment Committee adopted opinions supporting classification of trifluoroacetic acid and its inorganic salts as reproductive toxicants category 1B and as PMT and vPvM. These are the first RAC opinions backing harmonised PMT/vPvM classifications under the new hazard classes. The file now passes to the Commission, which decides whether and when to bring them in through a future ATP. TFA can form through the degradation of certain fluorinated pesticides and refrigerants, meaning that portfolio assessment needs to consider degradation pathways as well as the direct TFA use.
At the same meeting, RAC also supported classifying resorcinol as an endocrine disruptor for human health. Same status: an opinion, not a binding entry.
EFSA then reached the same molecule from a different direction. On 22 July it cut the acceptable daily intake for TFA from 0.05 to 0.014 mg per kilogram of body weight per day (roughly a 3.5-fold reduction) and set an acute reference dose of 0.07 mg/kg, citing evidence that TFA alters thyroxine levels. That is not a classification or a product limit, but the Commission and Member States are expected to use it when drinking water thresholds are revisited. Three regulatory systems are therefore now converging on one degradation product.
None of this is the universal restriction. Much of it applies sooner, and the rest is already shaping portfolio decisions.
What not to miss
- If you manage producer-register obligations in more than one Member State, review the draft implementing act and submit feedback before 10 September 2026.
- Pull the bill of materials for food-contact packaging types and obtain per-layer supplier data against the Article 5(5) limits. For each type, confirm the Article 38 conformity assessment is done, the Annex VII technical documentation compiled and the Article 39 EU declaration of conformity issued.
- Treat total fluorine as the screening method customers will ask about, harmonised method or not, and note that the Swedish draft shifts the burden of rebutting it onto the supplier.
- Map TFA exposure across the portfolio now. The RAC opinion is not binding and the Commission has still to decide whether and when to fold the classifications into an ATP — which makes this the planning window rather than the response window.
Sources: EUR-Lex — Regulation (EU) 2025/40 · European Commission — PPWR guidance and FAQ · EFSA — lower safe level for TFA
4. Concerning Biocides
Regulators extended biocides deadlines this summer, and neither removed an obligation.
Regulation (EU) 2026/1165 came into force on 15 June, extending data protection to 31 December 2030 for active substance and product-type combinations where the approval decision had not been adopted by 7 June 2018 — an acknowledgement of how far the Review Programme has slipped. It carries a provision worth reading closely: data owners may seek compensation from suppliers who benefited from the brief unprotected window between 1 January and 15 June 2026.
In Great Britain, HSE confirmed that active substance combinations with expiry dates falling between 23 June 2026 and 30 July 2031 are extended to 31 July 2031, provided the renewal application was submitted and accepted on time. The extension is conditional: submission alone does not secure it.
Against that, the submission standard tightened. From 1 July, all applications to renew biocidal active substance approvals under EU BPR must carry approval data in IUCLID format. The long-standing practice of accepting unstructured legacy Review Programme data has ended, and non-compliant dossiers are rejected at validation.
Ethanol remains the file to watch. The Biocidal Products Committee adopted supportive opinions for PT1, PT2 and PT4 in February, and the Commission is preparing a draft Implementing Regulation. The carcinogenicity and reproductive-toxicity question is now parked. If approval is formalised, product authorisation applications will follow, and the queue for those will not be short.
What not to miss
- Identify which active substance and product-type combinations benefit from the EU data protection extension — and check whether you have a compensation claim arising from the 1 * January to 15 June 2026 window.
- Any renewal dossier submitted from 1 July must be fully structured in IUCLID and pass the Validation Assistant before submission.
Sources: ECHA — biocides renewals in IUCLID · HSE — biocides expiry postponements
5. Revising REACH Revision
This story is older than the other four. The past years were spent in anticipation of the REACH Revision. Every conference had a presentation, a panel, or at least a comment on REACH Revision. We held a REACH Revision Roundtable last May and discussed the potentials of the reform at PCMC2026 extensively. And yet, Environment Commissioner Roswall confirmed in late April that the Commission will not bring forward a full legislative revision of REACH. Mandatory polymer registration, a ten-year registration validity and broad reform of the authorisation system are no longer being advanced through a comprehensive REACH revision. Simplification runs through comitology instead.
What that means in practice has already surfaced over the summer. REF-14 is in its 2026 operational inspection phase, with authorities across Member States checking CLP classification and labelling, packaging including child-resistant closures, PCN notifications and UFI codes, and SDS completeness, concentrated in consumer categories with a history of non-compliance. ECHA’s fourth REACH and CLP operation report, covering 2021 to 2025, describes a framework past its build-out phase and into maintenance and scrutiny.
On 17 August, the EU notified the WTO of a draft CLP amendment implementing GHS Revisions 8, 9 and 10 and selected provisions of Revision 11, including changes concerning aerosols and the classification of skin-sensitising mixtures, alongside broader technical updates to physical, health and environmental hazard criteria and hazard communication.
The EU is committed to implementing GHS revisions, yet it still changes classification outcomes. Adoption is planned for the fourth quarter of 2026, and stakeholder comments may be submitted until 16 October 2026.
So instead of the obligations, what changed is the probability of someone checking.
What not to miss
- If you place hazardous mixtures into consumer channels, audit label accuracy, PCN and UFI status and SDS quality now rather than after contact from an inspector.
- Stop planning around REACH 2.0. The dossier you have already filed is the one that will be examined.
Sources: European Parliament — REACH revision file
Already on the calendar
A few dates ahead, labelled by status.
7–16 September 2026 — ECHA committees meet SCHEDULED Three of the files above return to committee within a fortnight. The Biocidal Products Committee sits 7–10 September, the Committee for Risk Assessment 7–11 September, and the Committee for Socio-Economic Analysis 15–16 September. BPC is where the ethanol opinions were adopted in February, RAC is where the TFA and resorcinol opinions came from in June, and SEAC is where the PFAS restriction opinion is expected around the end of the year. Draft agendas (linked above) are published at least 21 days before each BPC meeting, so it is worth checking whether one of your substances is listed rather than reading about it afterwards. The Member State Committee and the Enforcement Forum meet later in the autumn.
1 October 2026 — PIC controls expand to more than 30 chemicals >BINDING
Commission Delegated Regulation (EU) 2026/1278, adopted on 9 June and applicable from 1 October 2026, amends Annexes I and V of the PIC Regulation. More than thirty substances are affected and, depending on the relevant entry, an export may require notification, may additionally require the importing country’s explicit consent, or may be prohibited outright. Among them are UV absorbers, chromium compounds, phthalates, trichloroethylene, MOCA, Dechlorane Plus and a number of pesticide actives. Existing entries are corrected too, including carbosulfan. ECHA has already loaded the new entries into ePIC, so notifications for October exports can already be prepared now.
1 November 2026 — CLP new hazard classes >BINDING
Under Delegated Regulation (EU) 2023/707, substances already on the market must carry updated classifications, labels and safety data sheets against the endocrine disruptor, PBT, vPvB, PMT and vPvM criteria by 1 November 2026. Mixtures follow on 1 May 2028. It applies to substances you have been selling for years rather than to new placements, and it is self-classification — you do not get to wait for a harmonised entry. The RAC opinion on TFA described above is the first recommendation for a harmonised PMT/vPvM classification. It is not yet an Annex VI entry, and the 1 November duty does not depend on it.
Q4 2026 — Toy Safety Directive amendment >PROPOSAL
The Commission has notified the WTO of a draft amending Directive 2009/48/EC. Lilial moves to the prohibited list, and the bisphenol A migration limit for mouthable toys and toys for children under 36 months drops from 0.04 mg/L to 0.005 mg/L. Requirements for BIT and phenol are revised, and the mandatory references to EN 71–10 and EN 71–11 are deleted; the EN 71–17/18/19 series may subsequently be assessed and cited for presumption of conformity. Comments close 10 October, with application twelve months after publication. Note that reformulation lead times for plastics and coatings are usually longer than that.
11 May 2027 — 2,4-dinitrotoluene restriction begins >BINDING · PHASED TO 2029
Regulation (EU) 2026/859 added Entry 83 to REACH Annex XVII in April. After 10 May 2027, articles containing 2,4-dinitrotoluene at or above 0.1 % by weight may not be placed on the market or used where they are intended for the general public or for professional users operating outside industrial sites. It closes the gap allowing imported articles to escape authorisation requirements EU manufacturers have carried since 2015. Articles already on the market before 11 May 2027 are not affected, and Entry 83 carries exemptions including articles for military use, ammunition for police and other security forces, toys, medical devices and food-contact materials. The automotive exposure runs on a longer clock: micro gas generators for seat belt pre-tensioners and bonnet actuators, and motor-vehicle spare parts, are deferred to 11 May 2029.
Q3 2028 — proposed 20-substance GB MCL entries become mandatory >PROPOSAL
Distant, and still only a proposal, but it sets the direction described in the first story: HSE revising the GB list on its own schedule rather than tracking EU harmonised classification. Adoption is expected in the first quarter of 2027, with mandatory application from the third quarter of 2028.
Sources: EUR-Lex — Regulation (EU) 2026/859 (2,4-DNT) · European Commission — Toy Safety TBT notification · EUR-Lex — Delegated Regulation (EU) 2023/707
Unsure whether or not do any of these changes apply to you?
And just like that, it’s a wrap. Thank you for reading and thank you to Jana Eliášová and Yana Trubitsyna for revision and edition work.