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Regulatory Updates

Structured summaries of relevant developments in EU product compliance. They explain what changed, when it applies, and who it affects.

PPWR April 2026

PPWR substances of concern: the PFAS ban is fixed for August 2026. A broader SoC list still depends on the ECHA report.

Regulation (EU) 2025/40 introduces two separate layers of chemical restrictions for packaging. The first is already fixed in law. From 12 August 2026, food contact packaging may not contain PFAS above defined thresholds. The second layer is broader and still under development. It concerns substances of concern across packaging types. ECHA launched a call for evidence in September 2025, and the Commission, supported by ECHA, must submit a report by 31 December 2026. That report may lead to further restrictions under the PPWR or REACH. Until then, the broader SoC framework remains open.

Legal basis Regulation (EU) 2025/40, Article 5 on substances of concern, and Article 5(5) on PFAS restrictions in food contact packaging.
What applies from 12 August 2026 PFAS in food contact packaging: max. 25 ppb per individual PFAS (targeted analysis); max. 250 ppb for sum of PFAS.
Heavy metals (Pb, Cd, Hg, Cr VI): combined max. 100 mg/kg in all packaging (unchanged from Directive 94/62/EC).
What is still pending The Commission and ECHA report on substances of concern in packaging is due by 31 December 2026. It may lead to further restrictions under the PPWR or REACH. Beyond PFAS and heavy metals, no final SoC list exists yet.
ECHA process The call for evidence on substances in packaging was launched on 17 September 2025 and closed on 28 October 2025. Its results feed into the Commission report due at the end of 2026.
Who is affected All manufacturers and importers of food contact packaging are directly affected, with immediate attention required for PFAS. Manufacturers of all packaging types should also monitor the wider ECHA and Commission process on substances of concern.
Action Test food contact packaging for PFAS now using the Commission's stepwise approach (total fluorine screening, then targeted analysis if >50 ppm). Map all substances of concern across packaging portfolio in preparation for the broader SoC report.
PPWR April 2026

The Commission publishes PPWR guidance and FAQs. This comes 4 months before the application date.

On 30 March 2026, the European Commission published its first comprehensive guidance package for Regulation (EU) 2025/40. It includes an interpretative guidance document, an annex, and a FAQ catalogue. The package addresses key areas that required clarification before August 2026. These include the definition of packaging, role allocation across the supply chain, PFAS restrictions for food contact packaging, recyclability timelines, packaging minimisation, reuse targets, and the relationship between the PPWR and the Single Use Plastics Directive. The guidance does not amend the regulation, but it provides the Commission’s interpretation to support more consistent application across the EU.

Published 30 March 2026. Commission reference IP/26/664.
Applies from 12 August 2026 for the general application of the PPWR. Further provisions apply in stages through 2040.
Who is affected All economic operators placing packaging on the EU market, including manufacturers, importers, producers, distributors, and online marketplaces.
Action The guidance should be reviewed to verify role classification, confirm the PFAS status of food contact packaging, and assess reuse and recyclability obligations before August 2026.
DPP March 2026

ISO and IEC announce a new Joint Technical Committee for Digital Product Passport standards.

ISO and IEC have established a new Joint Technical Committee, ISO/IEC JTC 5, for Digital Product Passport standards. The committee focuses on cross sector interoperability, the DPP system framework, and the wider DPP ecosystem. Eight harmonised standards for DPP data and interoperability are expected by 2026. These standards are intended to support the technical infrastructure required for ESPR related DPP obligations from 2027 onwards. The EU digital registry is expected to be operational by July 2026.

Status The creation of ISO/IEC JTC 5 was announced in March 2026. The committee is being established and the relevant standards are in development. CEN/CLC JTC 24 at EU level has already been active since Q3 2023.
Key milestone The EU digital registry is expected to be operational by July 2026. The first DPP obligations, for batteries, start in February 2027.
Who is affected All companies preparing DPP implementation, especially technology providers, manufacturers, and compliance teams.
Action The work of ISO/IEC JTC 5 should be monitored closely. DPP data architecture should be aligned with ISO/IEC 15459:2015 on unique identifiers and with the upcoming interoperability standards.
REACH March 2026

Universal PFAS restriction. ECHA proposal under review.

ECHA’s universal restriction proposal for PFAS under REACH is moving through the regulatory process. If adopted, it would become one of the broadest chemical restrictions in EU history and would affect a very large number of product categories. A final decision is not expected before 2026 or 2027.

Status The proposal is under review. No binding decision has been taken yet.
Who is affected Manufacturers using PFAS in products, textiles, coatings, or packaging.
Action PFAS substance mapping across the supply chain should begin now.

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BWBR July 2025

Battery due diligence postponed to 2027. Regulation (EU) 2025/1561 amends Regulation (EU) 2023/1542.

Regulation (EU) 2025/1561 postpones the battery due diligence obligations by two years. The rules on responsible sourcing, processing, and trading of cobalt, natural graphite, lithium, and nickel were originally due to apply from 18 August 2025. They now apply from 18 August 2027. The deadline for the Commission’s due diligence guidance has also been extended.

Legal basis Regulation (EU) 2025/1561, published in OJ L 2025/1561 on 30 July 2025, amending Regulation (EU) 2023/1542, Articles 48 to 52 on due diligence.
New deadline The due diligence obligations now apply from 18 August 2027 instead of 18 August 2025. The Commission guidance is due by 26 July 2026.
Who is affected Manufacturers and importers placing batteries on the EU market who source cobalt, natural graphite, lithium, or nickel through their supply chain.
Action The postponement does not remove the obligation. The additional time should be used to map critical raw material flows and build supply chain traceability infrastructure.
BWBR August 2026

Battery Regulation: harmonised labelling expands in August 2026. The Battery Passport becomes mandatory from February 2027.

Two major milestones under Regulation (EU) 2023/1542 are approaching. From 18 August 2026, harmonised labelling requirements expand. From 18 February 2027, all batteries must carry a QR code. For EV batteries, LMT batteries, and rechargeable industrial batteries above 2 kWh, that QR code must also provide access to the digital Battery Passport.

Legal basis Regulation (EU) 2023/1542, Article 13 on labelling and QR codes, Article 77 on the Battery Passport, Annex VI Part C, and Annex XIII.
Key dates 18 August 2026: expanded harmonised labelling. 18 February 2027: QR code mandatory on all batteries; Battery Passport mandatory for EV, LMT and industrial batteries >2 kWh.
Who is affected All manufacturers, importers, and distributors placing batteries on the EU market, regardless of battery type or origin.
Action Planning for Battery Passport infrastructure should start now. The QR code and passport system must be fully operational at the moment of market placement from February 2027.
Toys January 2026

New Toy Safety Regulation (EU) 2025/2509. The DPP replaces the Declaration of Conformity.

Regulation (EU) 2025/2509 was published in December 2025 and entered into force on 1 January 2026.. It replaces the Toy Safety Directive and introduces a mandatory Digital Product Passport for toys. The DPP must be accessible through a QR code, registered in the EU digital registry, and kept available for ten years after market placement. The regulation also tightens chemical requirements and introduces additional implications for connected and AI integrated toys.

In force 1 January 2026.
Applies from The Regulation entered into force on 1 January 2026.. The Toy Safety Directive is repealed 54 months later, which places full application around mid 2030.
Who is affected Manufacturers, importers, distributors, and online marketplaces selling toys for children under 14 in the EU.
Action DPP infrastructure should be planned early. Chemical formulations should be checked against the new prohibited substance lists. Obligations for connected toys should be reviewed in light of AI Act alignment.
NLF November 2025

European Product Act. The Commission is consulting on an overhaul of the NLF, CE marking, and market surveillance.

In November 2025, the European Commission launched two public consultations that are expected to feed into the planned European Product Act. One covers the New Legislative Framework. The other covers the Market Surveillance Regulation. The initiative is important because any reform of the NLF is likely to affect a large number of EU product laws. The Commission has also signalled that Digital Product Passports are expected to become a central compliance tool for CE marked products.

Source The Commission launched two public consultations on 12 November 2025. One covers the New Legislative Framework, and the other covers the Market Surveillance Regulation.
Consultations The consultations covered the New Legislative Framework, Decision No 768/2008/EC, and the Market Surveillance Regulation, Regulation (EU) 2019/1020. Both ran until 4 February 2026.
Key objectives Simplify documentation and conformity assessment obligations
Clarify rules for refurbished, remanufactured and second-life products
Integrate Digital Product Passport as central compliance tool across CE-marked products
Strengthen market surveillance and enforcement, including for e-commerce imports
Align definitions across 30 NLF-based legislative acts
Timeline Legislative proposal expected Q3 2026. Part of Commission Work Programme 2026.
Who is affected All manufacturers, importers and distributors placing CE-marked products on the EU market . the NLF underpins RED, LVD, EMC, Machinery, PPE, PED, MDR and 22 other EU product acts
Action Monitor Commission legislative proposal expected Q3 2026. Begin assessing DPP readiness as a replacement for Declaration of Conformity across your product portfolio.
RED August 2025

RED Art. 3(3)(d)(e)(f). Cybersecurity requirements are now mandatory for internet connected radio equipment.

Commission Delegated Regulation (EU) 2022/30, supplementing Directive 2014/53/EU (RED), has been applicable since 1 August 2025. It activates the essential requirements of Article 3(3)(d), (e) and (f) of the RED for defined categories of radio equipment . any device capable of communicating over the internet, whether directly or via another device. This includes smartphones, tablets, IoT devices, wearables, smart toys, and connected industrial equipment. The requirements cover protection of the network from harm, protection of personal data and privacy, and fraud prevention. Harmonised standards EN 18031-1, -2 and -3 were published in the Official Journal on 30 January 2025, but come with restrictions . manufacturers must carefully assess whether their product meets all conditions for self-declaration or whether Notified Body involvement is required. Delegated Regulation (EU) 2022/30 is scheduled for repeal on 11 December 2027, when the Cyber Resilience Act (EU) 2024/2847 takes over.

Legal basis Commission Delegated Regulation (EU) 2022/30 of 29 October 2021, supplementing RED 2014/53/EU, Art. 3(3)(d)(e)(f). Published OJ 12 January 2022. Applicable from 1 August 2025 (postponed from 1 August 2024 by Delegated Regulation (EU) 2023/2444).
Requirements Art. 3(3)(d): device must not harm the network or misuse network resources
Art. 3(3)(e): protection of personal data and privacy of user and subscriber
Art. 3(3)(f): protection from fraud (applies where device enables monetary transactions)
Harmonised standards EN 18031-1, EN 18031-2, EN 18031-3 . published OJ 30 January 2025 (Implementing Decision (EU) 2025/138). Listed with restrictions . full presumption of conformity only if all applicable clauses are met. Non-compliant with restrictions: Notified Body route required.
Next step Delegated Regulation (EU) 2022/30 repealed 11 December 2027 . replaced by Cyber Resilience Act (EU) 2024/2847 obligations from that date.
Who is affected Manufacturers, importers and distributors of internet-connected radio equipment . IoT devices, wearables, smart toys, connected home equipment, industrial radio equipment with internet connectivity
Action Verify scope of Delegated Regulation (EU) 2022/30 for your product. Assess EN 18031 restrictions. Confirm Module A self-declaration path or initiate Notified Body procedure. Prepare for CRA transition from December 2027.
PPWR August 2025

PPWR enters into force. The transitional periods begin.

Regulation (EU) 2025/40 on Packaging and Packaging Waste was published in the Official Journal and entered into force on 12 August 2025. Most obligations apply from 2030, but producer registration and reporting requirements under extended producer responsibility (EPR) start earlier. Companies placing packaging on the EU market should begin mapping their packaging portfolio now.

In force 12 August 2025
Applies from 12 August 2026 (most provisions); EPR obligations phased 2026–2030
Who is affected Manufacturers, importers, distributors placing packaged products on the EU market
Action Map your packaging portfolio, identify producer roles, prepare for EPR registration
RED August 2025

USB C common charger requirement. Full scope applies from 2026.

Under the Radio Equipment Directive amendment, USB-C charging became mandatory for most portable electronic devices from 28 December 2024. Laptops follow from 28 April 2026. The regulation covers smartphones, tablets, cameras, headphones, portable speakers and handheld game consoles.

Applies from 28 Dec 2024 (most devices); 28 April 2026 (laptops)
Who is affected Manufacturers and importers of portable consumer electronics
Action Verify product scope, update technical documentation and declaration of conformity
ESPR April 2025

The first ESPR working plan has been adopted. Priority product groups are confirmed.

The European Commission adopted the first ESPR working plan on 16 April 2025, covering a minimum of three years. Priority product groups include textiles, electronics, furniture, tyres, detergents and steel. The plan sets the timeline for delegated acts that will establish product-specific ecodesign requirements.

Adopted 16 April 2025
Who is affected Manufacturers of textiles, electronics, furniture, tyres, steel, detergents
Action Check if your product category is in the first working plan and monitor upcoming delegated acts
AI Act February 2025

AI Act. The rules on prohibited practices now apply.

From 2 February 2025, the provisions on prohibited AI practices under Regulation (EU) 2024/1689 became applicable. This includes bans on AI systems that use subliminal manipulation, exploit vulnerabilities, or enable social scoring by public authorities. Obligations for general-purpose AI models apply from August 2025.

Applies from 2 February 2025 (prohibited practices); 2 August 2025 (GPAI models)
Who is affected Providers and deployers of AI systems in the EU
Action Audit AI systems in use for prohibited practice compliance
CPR January 2025

New Construction Products Regulation (EU) 2024/3110. This is a full recast, not just an amendment.

Regulation (EU) 2024/3110 was published in the Official Journal on 18 December 2024 and entered into force on 7 January 2025. It fully repeals and replaces CPR 305/2011. It is a comprehensive recast. It adds mandatory sustainability indicators, a legal basis for Digital Product Passports, stronger CE marking rules, and a revised framework for market surveillance and enforcement.

Published Published in the Official Journal on 18 December 2024. In force since 7 January 2025.
Applies from Most provisions apply from 8 January 2026. Penalties under Article 92 apply from 8 January 2027. The old CPR 305/2011 is fully repealed from 8 January 2040.
Key changes Mandatory declaration of Global Warming Potential (GWP) from January 2026 (Annex II a–d)
Expanded sustainability indicators from January 2030 (Annex II e–m)
Full life cycle environmental reporting from January 2032 (Annex II a–s)
Legal basis for Digital Product Passports — details via delegated acts expected post-2026
37 product families in Annex IV replacing old product families
Strengthened market surveillance and enforcement with penalties
Parallel regime The old CPR 305/2011 continues to apply for products still covered by harmonised standards under the previous regime until new harmonised standards are issued under the new CPR.
Who is affected Manufacturers, importers, and distributors of products intended for permanent incorporation into buildings or civil engineering works in the EU.
Action The relevant product family should be identified in Annex IV. Companies should check whether harmonised technical specifications already exist under the new CPR and prepare for the first sustainability related obligations from January 2026.
GPSR December 2024

GPSR replaces the GPSD. It adds new obligations for online marketplaces.

The General Product Safety Regulation (EU) 2023/988 became fully applicable on 13 December 2024. and replaced the General Product Safety Directive. Key changes include mandatory internal accident reporting, new obligations for online marketplace operators, and stricter requirements for the EU Responsible Person.

Applies from 13 December 2024.
Who is affected All economic operators, online marketplace operators, and importers without an EU establishment.
Action The setup for the EU Responsible Person should be reviewed. Technical documentation and recall procedures should also be updated.
Machinery July 2023

New Machinery Regulation (EU) 2023/1230. It replaces Machinery Directive 2006/42/EC from January 2027.

Regulation (EU) 2023/1230 was published on 29 June 2023 and entered into force on 19 July 2023. It replaces the Machinery Directive fully. It applies from 20 January 2027 with no overlapping transitional regime after that date. It is also the first EU machinery legislation to address AI, cybersecurity, and digitally connected systems explicitly.

Published Published in the Official Journal on 29 June 2023. In force since 19 July 2023.
Applies from 20 January 2027 is the hard application date. There is no transitional overlap after that point. Machinery Directive 2006/42/EC remains applicable until 19 January 2027.
Key changes Directive → Regulation: directly binding, no national transposition, uniform application across all EU states
AI and cybersecurity: first machinery legislation to include explicit requirements for AI-integrated and digitally connected machinery
Control systems: new requirements for safety-related control systems including traceability log for safety software versions
Digital instructions: manufacturers may now provide user instructions in digital format
Importer and distributor obligations: aligned to New Legislative Framework (NLF) — new obligations for importers and distributors previously not applicable under the Directive
Annex I (high-risk machinery): six categories requiring mandatory third-party conformity assessment — applying harmonised standards does not remove this obligation
Substantial modification: clarified definition — modifiers may become manufacturers with full obligations
Market surveillance: strengthened procedures and updated conformity assessment routes
Who is affected Manufacturers, importers, and distributors of machinery, related products, safety components, partly completed machinery, and interchangeable equipment placed on the EU market.
Action A gap analysis against the essential requirements of the new Regulation should be carried out, especially for control systems, AI and cybersecurity, and documentation formats. It should also be checked whether the product falls under Annex I and therefore requires mandatory third party conformity assessment.
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Entries are based on primary sources — Official Journal publications, European Commission announcements, and standardisation body communications. No interpretation beyond what is stated in the source document.

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