Chemicals | Monthly bulletin | January 2026


France adopts new decree to ban PFAS in consumer products
On the 30th of December 2025, the French government published Decree No. 2025-1376, introducing strict measures to prevent risks associated with perfluoroalkyl and polyfluoroalkyl substances (PFAS).
The decree applies to a wide range of products, including cosmetics, textiles, footwear, and waterproofing agents. Under this regulation, the manufacture, import, export, and marketing of products containing PFAS are prohibited as of 1 January 2026. A transitional period of 12 months is granted for the sale of existing stock produced prior to this date. The decree specifies residual concentration thresholds for PFAS as follows:
- 25 ppb for individual PFAS (excluding polymers)
- 250 ppb for the sum of PFAS (with prior degradation of precursors, excluding polymers)
- 50 ppm for total fluorine content (including polymers)
If the total fluorine measurement exceeds 50 mg F/kg, the manufacturer, importer, exporter, or producer must provide, upon request from the competent authorities, proof that the fluorine content originates from PFAS or non-PFAS substances.
Certain exemptions are allowed, notably for:
- Personal protective equipment (PPE) under EU Regulation 2016/425
- Military and civil protection gear
- Textiles and footwear incorporating at least 20% recycled material, where PFAS presence is limited to the recycled portion
This decree implements the provisions made in Law No. 2025-188, which was adopted in 2025 to protect public health and the environment from PFAS-related risks. The regulation aligns with EU standards and anticipates future technical updates under European chemical safety regulations. The Ministry of Ecological Transition emphasised that these measures aim to reduce PFAS exposure, which has been linked to environmental persistence and potential health hazards.
New exemptions under the Restriction of Hazardous Substances (RoHS)
On the 21st of November 2025, the European Commission published several delegated directives amending Annex III to Directive 2011/65/EU on the use of certain hazardous substances in electrical and electronic equipment. These publications specify the applications exempted from the restrictions, as well as the scope and dates of applicability. For further details, please refer to the following official documents:
- Commission Delegated Directive (EU) 2025/1802 of 8 September 2025 amending Directive 2011/65/EU of the European Parliament and Council regarding an exemption for lead in high melting temperature solders.
- Commission Delegated Directive (EU) 2025/2363 of 8 September 2025 amending Directive 2011/65/EU of the European Parliament and Council regarding an exemption for lead in glass or ceramic components.
- Commission Delegated Directive (EU) 2025/2364 of 8 September 2025 amending Directive 2011/65/EU of the European Parliament and Council regarding an exemption for lead as an alloying element in steel, aluminium and copper.
The provisions set forth in these directives shall apply from 1 July 2026.
On the 12th of December 2025, another relevant document related to the Restriction of Hazardous Substances (RoHS) Directive was published. The European Union implemented Directive (EU) 2025/2456, amending the RoHS Directive (2011/65/EU) to transfer key scientific and technical responsibilities to the European Chemicals Agency (ECHA). This directive promotes the “one substance, one assessment” principle, reduces duplication of effort, and enhances transparency. By consolidating scientific tasks under ECHA, the EU aims to accelerate decision-making, protect human health and the environment, and support innovation.
For full details, consult the official text of Directive (EU) 2025/2456 on EUR-Lex here.
EU Regulation on export and import of hazardous chemicals updated
On the 1st of March 2025, the European Commission consolidated and updated Regulation (EU) No 649/2012, which governs the export and import of hazardous chemicals within the European Union. This regulation implements the Rotterdam Convention on the Prior Informed Consent (PIC) procedure for certain hazardous chemicals and pesticides in international trade.
The updated text reinforces the EU’s commitment to:
- Protect human health and the environment by controlling the movement of hazardous chemicals.
- Ensure shared responsibility and transparency in international chemical trade.
- Align terminology and provisions with related EU legislation, including REACH and the CLP Regulation.
Key provisions include:
- Export Notification Requirements for chemicals banned or severely restricted in the EU.
- PIC Notifications for chemicals qualifying under the Rotterdam Convention.
- Import Decisions based on Union legislation and international obligations.
- Export Bans on certain chemicals and articles listed in Annex V, including persistent organic pollutants and mercury-containing products.
The regulation also mandates technical assistance, information exchange, and enforcement measures to ensure compliance across Member States. It applies to hazardous chemicals in pure form, mixtures, and certain articles, with specific exemptions for research quantities.
For full details, consult the Official Journal of the European Union or access the consolidated text via EUR-Lex here.
New EU Regulation establishes chemical data platform
Effective January 2026, the European Union has introduced a centralised data platform to enhance chemical safety and transparency.
The European Parliament and Council have adopted Regulation (EU) 2025/2455, creating a unified EU Chemicals Data Platform managed by the European Chemicals Agency (ECHA). This initiative supports the EU’s Green Deal and Chemicals Strategy for Sustainability, aiming for a toxic-free environment and improved regulatory efficiency.
The platform will integrate data from ECHA, EFSA, EMA, EU-OSHA, and other EU bodies, while safeguarding confidential information.
This regulation marks a step toward digital transformation in chemical safety, aligning with the EU’s European Data Strategy and Green Deal Data Space.
For full details, read Regulation (EU) 2025/2455 on EUR-Lex here.
EU enhances scientific cooperation on chemicals
On the 12th of December 2025, the European Parliament and the Council adopted Regulation (EU) 2025/2457, which introduces amendments to several key legislative acts to enhance scientific and technical collaboration across EU agencies in the field of chemicals by streamlining scientific and technical tasks under the European Chemicals Agency (ECHA). This change supports the ‘one substance, one assessment’ principle and aligns with the Chemicals Strategy for Sustainability and the European Green Deal. The main points are:
- Centralisation of expertise: ECHA will take on tasks previously shared with EFSA, EMA, and other agencies.
- Improved risk assessment: Ensures consistency and efficiency in evaluating chemical safety.
- Legislation updated: Includes amendments to food law, contaminants regulation, medical devices, and persistent organic pollutants.
This reform aims to protect health and the environment, increase transparency, and accelerate regulatory processes.
For full details, read Regulation (EU) 2025/2457 on EUR-Lex here.
EU adopts regulation to prevent plastic pellet losses and combat microplastic pollution
On the 26th of November 2025, the European Union has introduced Regulation (EU) 2025/2365, a comprehensive legal framework aimed at preventing plastic pellet losses throughout the supply chain to reduce microplastic pollution. This regulation establishes binding obligations for manufacturers, carriers, and shippers handling plastic pellets in quantities above five tonnes annually.
Under the new rules, companies must:
- Implement risk management plans and preventive measures at all handling stages.
- Train staff and maintain records of estimated annual pellet losses.
- Notify competent authorities and, for large operators, obtain certification of compliance.
- Adopt stricter packaging and stowage requirements for maritime transport.
The new rules will apply from 17 December 2027, with certain obligations, such as designation of competent authorities and development of harmonised standards, as of December 2025. The initiative supports the EU’s Zero Pollution Action Plan, which targets a 30% reduction in microplastic emissions by 2030.
For full details, visit the official EUR-Lex page: Regulation (EU) 2025/2365.
Recent publications on REACH Regulation
The following table provides a non-exhaustive summary of some recent updates regarding REACH Regulation (EC) No 1907/2006:
|
Summary of the most recent updates |
||
|
Date |
Subject |
Link |
|
26/11/2025 |
Companies are required to begin reporting their annual microplastic emissions to the European Chemicals Agency (ECHA) in accordance with the European Union’s microplastics restriction. These reporting obligations apply exclusively to uses that are exempt from the EU-wide prohibition. The initial reports must be submitted no later than 31 May 2026 and should include estimated emissions for the calendar year 2025. |
For more information, consult the ECHA website here. |
|
03/12/2025 |
The EU Observatory for Nanomaterials published several articles related to nanomaterials and consumer products as textiles. |
For more information, consult the ECHA website here. |
|
10/12/2025 |
The European Chemicals Agency (ECHA) has published the results of Forum REF-12, an EU-wide targeted enforcement project revealing significant non-compliance with REACH requirements among imported substances, mixtures, and consumer products. Inspectors in 29 EEA countries conducted 2,603 targeted controls in cooperation with customs and national enforcement authorities. |
For more information, consult the report in ECHA website here. |
|
10/12/2025 |
Publication on question and answers about the restriction of Cr (VI) substances under REACH. |
Consult the Q&A in European Commission publication here. |
|
15/12/2025 |
ECHA’s Member State Committee December meeting highlights. |
For more information, consult the ECHA website here. |
|
16/12/2025 |
ECHA launches public consultation on potential candidates for substitution and on derogation conditions.
|
For more information, consult the ECHA website here. |
|
17/12/2025 |
ECHA published the annual data reported by Member States on exports and imports in 2024 of chemicals listed in Annex I of the Prior Informed Consent (PIC) Regulation.
ECHA observes a fall in hazardous chemical trade in 2024. The decline is mainly due to reduced volumes of exports and imports of substances containing benzene. |
For more information, consult the ECHA website here. |
|
19/12/2025 |
Commission Regulation (EU) 2025/2573 of 18 December 2025 amends Regulation (EC) No 440/2008 as regards the test methods, adapting them in line with technical progress. |
For more information, consult the European Commission website here. |
Interesting resources on REACH Regulation on the ECHA’s website
- Registry of restriction intentions until outcome - ECHA (europa.eu)
- Registry of SVHC intentions until outcome - ECHA (europa.eu)
- Substance evaluation - CoRAP - ECHA (europa.eu)
- Adopted opinions and previous consultations on applications for authorisation - ECHA (europa.eu)
- Applications for authorisation - current consultations - ECHA (europa.eu)
- Current calls for comments and evidence - ECHA (europa.eu)
- Authorisation List - ECHA (europa.eu)
- ECHA's completed activities on restriction
- Submitted restrictions under consideration
- Assessment of regulatory needs list
ECHA Committees make significant progress on PFAS restriction and vPvB classification
On the 17th of December 2025, the European Chemicals Agency (ECHA) has announced pivotal developments following the December meetings of the Committee for Risk Assessment (RAC) and Committee for Socio-Economic Analysis (SEAC).
The ECHA website provides the following documents on PFAS use mapping and highlights from the RAC and SEAC meetings in December:
For more details, consult the ECHA’s website here.
Recent publications on CLP Regulation
The following table provides a non-exhaustive summary of some recent updates regarding CLP Regulation (EC) No 1272/2008:
|
Summary of the most recent updates |
||
|
Date |
Subject |
Link |
|
27/11/2025 |
The European Commission submitted notification G/TBT/N/EU/1172 to the World Trade Organization (WTO), announcing a forthcoming technical amendment to the Classification, Labelling and Packaging (CLP) Regulation (EC No. 1272/2008). The proposed amendment includes the addition of 38 new entries and the revision of 10 existing entries in Annex VI.
The regulation is expected to be adopted in the first quarter of 2026 and will enter into force 20 days following its publication in the Official Journal of the European Union. An 18-month transitional period will be granted to industry to ensure compliance. |
For full details, visit the official WTO website here.
|
|
10/12/2025 |
Notice concerning the harmonised classification of titanium dioxide as Carcinogenic Category 2 via inhalation according to Regulation (EC) No 1272/2008 of the European Parliament and Council. |
For more information, consult the European Commission publication here. |
Interesting resources on the CLP Regulation on the ECHA’s website
- Registry of CLH intentions until outcome - ECHA (europa.eu)
- Harmonised classification and labelling consultations - ECHA (europa.eu)
EU Council gives final approval of updated Detergents and Surfactants Regulation
On the 8th of December 2025, the Council of the European Union formally endorsed the revised Detergents and Surfactants Regulation. The existing Detergents Regulation has been in place since 2004 and is being updated to resolve overlaps with other EU chemical legislation and to improve consumer safety, information clarity, and environmental protection.
The Council’s first-reading approval constitutes the final step at this stage. The draft text now proceeds to a plenary vote in the European Parliament. Following its entry into force, the regulation will become applicable three and a half years later, allowing for an implementation period to facilitate industry compliance.
For more details, consult the European Council website here.
EU Launches “One Substance–One Assessment” Regulatory Framework
On 12 December 2025, the European Union formally published the final One Substance–One Assessment (OSOA) regulatory package in the Official Journal—a major reform aimed at enhancing chemical governance across Europe. The package will enter into force on 1 January 2026. the key Elements of the OSOA Package are:
Establishes a centralized EU chemicals data platform, ensuring that data is findable, accessible, interoperable, and reusable (FAIR). It also sets up a monitoring and outlook framework for chemicals.
Assigns clearer scientific and technical responsibilities among EU agencies (including EFSA and ECHA), and introduces a procedure to reconcile conflicting risk assessments.
Amends Directive 2011/65/EU to reallocate scientific and technical evaluation tasks to the European Chemicals Agency (ECHA), reinforcing its central role in chemical risk assessments.
The OSOA package underpins the EU's commitment to efficient, transparent, and science-based chemical policy. It supports the European Green Deal's zero pollution ambition and promotes safer, more sustainable chemicals throughout European markets.
For more information about European Chemicals Strategy, consult the European Commission website here.
Switzerland strengthens chemical safety with updates to ORRChem Ordinance
On the 21st of November 2025, Switzerland implemented substantial amendments to its Chemical Risk Reduction Ordinance (ORRChem; RS/SR 814.81 (DE, FR, IT)) with the publication of Official Collection (RO 2025 747 (DE, FR, IT)) by the Federal Office for the Environment.
The revised ordinance introduces several key enhancements designed to align Swiss regulations more closely with European Union chemical safety standards, particularly those under EU REACH and related persistent organic pollutants (POPs) legislation.
Key amendments to ORRChem:
|
Topics |
Changes |
|
Persistent Organic Pollutants (POPs) |
Prohibitions in Annex 1.1 now specifically include PFOS, PFHxS, PFOA, and their derivatives. |
|
Annex 1.1 expanded to incorporate PFHxS-related compounds, Dechlorane Plus (DP), methoxychlor, and UV-328, introducing temporary derogations for DP and UV-328. |
|
|
PFAS Restrictions |
Annex 1.16 now defines and regulates PFHxA and related substances, enforcing maximum thresholds of 25 ppb for PFHxA and 1,000 ppb for related compounds across cosmetics, food-contact materials, textiles, leather, and general-use mixtures.
|
|
Microplastics and PVC Additives |
A revamped Annex 2.9 addresses synthetic polymer microparticles (microplastics) and aligns PVC lead limits (< 0.1 %) with those established in Annex XVII of REACH. |
|
Formaldehyde Emissions |
Annex 2.17 sets formaldehyde limits: ≤ 0.062 mg/m³ for furniture, wood-based articles, and vehicle interiors; and ≤ 0.08 mg/m³ for other products.
|
|
Additional Updates |
Amendments also affect annexes on halogenated organic substances, ozone-depleting chemicals, air-stable substances, REACH Annex XIV substances, detergents, cleaning products, solvents, refrigerants, aerosol generators, and insulating gases. |
Implementation will occur in phases, having begun on the 1st December 2025, allowing affected industries time to align with the updated standards.
Connecticut Approves Official Wording for PFAS Labels
In a significant regulatory milestone under its PFAS in Products law (Connecticut General Statutes § 22a-903c), the Connecticut Department of Energy and Environmental Protection (DEEP) has published an approved list of consumer-facing labeling phrases that manufacturers, producers, wholesalers, and retailers must use to disclose the presence of intentionally added per- and polyfluoroalkyl substances (PFAS) in products sold in the state.
Connecticut’s PFAS in Products law, enacted as part of Public Act 24-59 in 2024, establishes a phased approach to disclosure and eventual prohibition of certain categories of products that contain intentionally added PFAS. This law is designed to give consumers clear, visible notice about PFAS content and to reduce exposure to “forever chemicals” in everyday products.
Beginning July 1, 2026, covered products containing intentionally added PFAS may only be sold or offered for sale in the state if they carry a label with terminology approved by DEEP that informs the purchaser of the presence of PFAS in the product.
Approved Labeling Phrases
On December 1, 2025, DEEP issued an order approving the following wording that satisfies the state’s PFAS labeling requirement:
- “Contains PFAS”
- “Made with PFAS”
- “Made with PFAS chemicals”
- “Made with intentionally added PFAS”
- “This product contains PFAS chemicals”
These phrases are now official and may be used on product labels to meet the disclosure requirement under the law.
DEEP has also clarified that other words or symbols may be approved on a case-by-case basis if a manufacturer petitions the agency and the proposed alternative satisfies the statutory criteria. Such petitions are submitted by email to DEEP’s PFAS in Products mailbox.
Which Products Are Covered
The PFAS labeling requirement applies to a broad range of consumer product categories that may contain intentionally added PFAS if manufactured on or after the compliance date. These include:
- Apparel
- Carpets or rugs
- Cleaning products
- Cookware
- Cosmetic products
- Dental floss
- Fabric treatments
- Juvenile products
- Menstruation products
- Textile furnishings
- Ski wax
- Upholstered furniture
The requirement also applies to any product category where PFAS-containing components are incorporated — meaning final assembled products containing covered components must also be labeled.
What the Labels Must Look Like
According to the statutory requirements and DEEP’s order:
- Labels must be clearly visible before the point of sale.
- They must inform the purchaser that PFAS are present using an approved phrase or symbol.
- Labels must be constructed of materials durable enough to remain legible for the product’s useful life.
The responsibility to apply the label lies with the manufacturer or producer unless the wholesaler or retailer agrees in writing to assume that responsibility.
Bans Mercury-Added Products Under Minamata Convention
On September 23, 2025, the Environmental Protection Bureau of Macao Special Administrative Region notify (G/TBT/N/MAC/33) the WTO officially banning the import, export, and transit of numerous mercury-added products.
The prohibition was mandated by Chief Executive Dispatch No. 109/2025, signed on June 9, 2025, and published in the Official Gazette on June 16, 2025.
The ban will officially take effect on January 1, 2026.
The Dispatch prohibits the import, export, and transit of the following categories of mercury-added products listed under the Minamata Convention:
- Electrical and Electronic Products
- Batteries
- Switches and Relays
- Mercury Vacuum Pumps
- Electrical and Electronic Measuring Devices, including:
- Melt pressure transducers
- Melt pressure transmitters
- Melt pressure sensors
- Lighting
The ban applies to several common and specialized mercury-containing lighting products for general illumination:
- Compact Fluorescent Lamps (CFLs) for general lighting purposes.
- High-Pressure Mercury Vapor Lamps (HPMV) for general lighting purposes.
- Straight and Non-Linear Fluorescent Lamps (U-shape and circular) for general lighting purposes, including:
- Triband phosphor lamps, all wattages.
- Halo phosphate phosphor lamps, all wattages.
- Cold Cathode Fluorescent Lamps (CCFL) and External Electrode Fluorescent Lamps (EEFL) used for electronic displays.
- Cosmetics, Pesticides, and Topical Agents
- Cosmetics, including skin lightening soaps and creams.
- Exemption: Eye area cosmetics that use mercury as a preservative when no effective and safe alternative preservatives are available.
- Pesticides, biocides, and topical antiseptics.
- Non-Electronic Measuring Devices and Other Products
- Non-electronic measuring instruments, including:
- Barometers
- Hygrometers
- Manometers
- Thermometers
- Sphygmomanometers (blood pressure monitors)
- Strain gauges used with plethysmographs.
- Tire balancers and wheel weights.
- Photographic film and paper.
Exemption for Research and Calibration
The prohibition does not apply to mercury-added products intended for use in research, for instrument calibration, or for serving as reference standards.
Proposed Control of 6 Mercury-Added Products Adopted under the Minamata Convention
On September 8, 2025, the National Environment Agency of Singapore notify (G/TBT/N/SGP/76) the WTO Proposed Control of 6 Mercury-Added Products Adopted under the Minamata Convention.
Singapore is a Party to the Minamata Convention. At the fifth Conference of Parties (COP-5) to the Minamata Convention in October 2023, 6 new mercury-added products were approved by the Parties for phasing out by 1 January 2027 (4 products) and 1 January 2028 (2 products). Singapore is proposing to control these 6 mercury-added products as Hazardous Substance under the Environmental Protection and Management Act (EPMA) to fulfil our Minamata Convention obligations.
The 6 mercury-added products can be found under Section 4 above. Mercury-added products listed as S/N 1-4 are planned for phasing out by 1 January 2027 while S/N 5-6 are planned for phasing out by 1 January 2028.
There is no change to the other existing regulatory requirements in the EPMA. Once the regulation takes effect, the import, export, and manufacture of the 6 mercury-added products will not be allowed.
The cover product please see follows:
|
S/N |
Chemical Name & Identity |
HS 2022 Code |
HS 2022 Description |
|
1 |
Compact fluorescent lamps (CFLs) for general lighting purposes that are > 30 watts |
85393110 |
Tubes for compact fluorescent hot cathode lamps excluding ultraviolet lamps |
|
85393130 |
Compact fluorescent hot cathode lamps with built-in ballast excluding ultraviolet lamps |
||
|
85393190 |
Other discharge fluorescent hot cathode lamps excluding ultraviolet lamps |
||
|
85393910 |
Other tubes for compact discharge fluorescent lamps |
||
|
85393990 |
Other discharge lamps excluding ultraviolet lamps |
||
|
2 |
Compact fluorescent lamps with a non-integrated ballast (CFL.ni) for general lighting purposes that are ≤ 30 watts with a mercury content not exceeding 5 mg per lamp burner |
85393110 |
Tubes for compact fluorescent hot cathode lamps excluding ultraviolet lamps |
|
85393190 |
Other discharge fluorescent hot cathode lamps excluding ultraviolet lamps |
||
|
85393910 |
Other tubes for compact discharge fluorescent lamps |
||
|
85393990 |
Other discharge lamps excluding ultraviolet lamps |
||
|
3 |
Linear fluorescent lamps (LFLs) for general lighting purposes:
1. Halophosphate phosphor ≤ 40 watts with a mercury content not exceeding 10 mg per lamp 2. Halophosphate phosphor > 40 watts |
85393120 |
Other straight tubes for other fluorescent hot cathode lamps excluding ultraviolet lamps |
|
4 |
Halophosphate phosphor non-linear fluorescent lamps (NFLs) (e.g., U-bend and circular) for general lighting purposes |
85393190 |
Other discharge fluorescent hot cathode lamps excluding ultraviolet lamps |
|
85393990 |
Other discharge lamps excluding ultraviolet lamps |
||
|
5 |
Triband phosphor non-linear fluorescent lamps (NFLs) (e.g., U-bend and circular) for general lighting purposes |
85393190 |
Other discharge fluorescent hot cathode lamps excluding ultraviolet lamps |
|
85393990 |
Other discharge lamps excluding ultraviolet lamps |
||
|
6 |
Linear fluorescent lamps (LFLs) for general lighting purposes:
1. Triband phosphor < 60 watts with a mercury content not exceeding 5 mg per lamp 2. Triband phosphor ≥ 60 watts with a mercury content not exceeding 5mg per lamp 3. Triband phosphor ≥ 60 watts with a mercury content exceeding 5mg per lamp |
85393120 |
Other straight tubes for other fluorescent hot cathode lamps excluding ultraviolet lamps |















































