Chemicals | Monthly bulletin | September 2025

Europe

Updated PFAS restriction proposal

In August 2025, The European Chemicals Agency (ECHA) published several updates related to per- and polyfluoroalkyl substances (PFAS).

The updated proposal to restrict PFAS under the European Union’s Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation was published on August 20th, following an initial proposal in January 2023. The update was drafted by the authorities from Denmark, Germany, the Netherlands, Norway and Sweden.

On the 27^th of August 2025, the ECHA announced a proposed timeline for PFAS restriction.

On the 27th of August 2025, the ECHA announced a proposed timeline for PFAS restriction. RAC and SEAC plan to conclude their discussions on the 14 sectors covered by the original restriction proposal, plus PFAS manufacturing and horizontal issues by the end of 2025 and deliver the final RAC and SEAC opinions to the European Commission in 2026.

On the other hand, the information from the consultation has also led to the identification of a further eight sectors.  However, including a further 8 sectors into the Committees’ evaluations now would require significant time beyond 2026 to finalise the opinion with these sectors. Therefore, in the ongoing procedure, the Committees will not carry out a sector specific evaluation of these further eight sectors.

For more information, consult ECHA’s website here.

Recent publications on REACH Regulation

The following table provides a non-exhaustive summary of some recent updates regarding REACH Regulation (EC) No 1907/2006:

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

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)

European initiatives related to hazardous chemicals

The table below summarises recent publications on the European Commission initiatives and their status regarding:

New dates for battery due diligence policies

On the 30th of July 2025, the European Commission published the amending Regulation (EU) 2023/1542 regarding the obligations of economic operators concerning battery due diligence policies, which came into effect on the 31^st of July 2025.

It modifies the dates of article 48 of Regulation (EU) 2023/1542 related to battery due diligence policies. The new dates are:

• From the 18^th of August 2027, economic operators that place batteries on the market or put them into service shall fulfil the due diligence obligations laid out in Articles 48, 49, 50 and 52 and shall, to that end, establishand implement battery due diligence policies.
• By the 26^th of July 2026, the Commission shall publish guidelines regardingthe application of the due diligence requirements laid down in Articles 49 and 50, with respect to the risks referred to in point 2 of Annex X, and in linewith the international instruments referred to in points 3 and 4 of Annex X.

France

Publication related to EPR for portable batteries and accumulators

In August 2025, The French Minister for Ecological Transition, Biodiversity, Forests, the Sea and Fisheries published several orders related to the production of portable batteries and accumulators  and the extended responsibility sector of these type of products. The orders are:

• Order of July 11, 2025, approving an eco-organisation for the extended producer responsibility sector for portable batteries and accumulators (ecosystem company). The ecosystem company is approved on the basis of the COREPILE company's application for approval to manage waste from portable batteries and accumulators. The benefit of this approval is granted to the ecosystem company, which undertakes to continue the activity of the COREPILE company as an approved eco-organisation for the management of waste from portable batteries and accumulators, and to take over and respect all the commitments made by the COREPILE company in particular..  (Text n° 28).
• Order of August 11, 2025, approving an eco-organisation for the extended producer responsibility battery sector (BATRIBOX). BATRIBOX is approved as an eco-organszation for all battery categories from August 18^th, 2025, until December 31^st, 2030. (Text nº 23).
• Order of August 11, 2025, approving an eco-organisation for the extended producer responsibility battery sector (ECOSYSTEM). ECOSYSTEM is approved for all battery categories as an eco-organisation from August 18^th, 2025, to December 31^st, 2030. (Text nº25).

French draft Decree defines PFAS limits and exemptions

On the 7^th of August 2025, the French Ministry of Ecological Transition, Biodiversity, Forests, the Sea and Fisheries notified the European Commission of a Decree related to the prevention of risks arising from PFAS exposure (2025/0431/FR).

This Decree is adopted pursuant to Article 1(1) of Law No 2025-188 of 27 February 2025 on the protection of the population from risks associated with PFAS. This Decree defines the PFAS concentration limit beyond which prohibitions apply, as well as outlining a list of products that are exempt from these prohibitions.

This Decree is expected to be published in December 2025.

Spain

New accessible labelling requirements

On the 20^th of June 2025, the Spanish Subdirectorate General for Regulation and Consumer Rights notified the European Commission of a Decree related to the accessible labelling of consumer products (2025/0311/ES).

The purpose of the Royal Decree is to regulate labelling to ensure that product information is universally accessible.

This labelling will apply to consumer goods such as cosmetic products, hazardous substances and mixtures/foodstuffs, which are of particular relevance to the safety, integrity and quality of life of persons with visual disabilities.

This Royal Decree aims to comply with the mandate of the law by regulating labelling in Braille, as well as in other inclusive formats for vulnerable consumers.

US

Minnesota extends PFAS reporting deadline by six months

The Minnesota Pollution Control Agency (MPCA) has announced a six-month extension to the initial reporting deadline under Amara’s Law—the state’s PFAS pollution prevention statute enacted in 2023. The new due date for manufacturers to submit PFAS-related product information is now July 1^st, 2026, six months from the original January 1^st, 2026 deadline.

The MPCA cited two primary reasons for the extension:

• Supplier coordination: manufacturers needed more time to establish agreements with suppliers to report PFAS data on their behalf—a permitted approach under the proposed rules.
• Platform readiness: the PFAS Reporting and Information System of Minnesota (PRISM), the web portal designated for reporting, will be available in late 2025, requiring additional familiarisation time for users.

According to the MPCA, these accommodations aim to enhance both the quality and completeness of PFAS data submitted.

Illinois enacts HB 2516: phasing out intentionally added PFAS from consumer goods

The state of Illinois approved House Bill 2516 on August 15^th, 2025, marking a major expansion of the state’s PFAS Reduction Act beyond Class B firefighting foams. The legislation phases out PFAS additives in key consumer products and tasks the Illinois Environmental Protection Agency (EPA) with reviewing the safety of fluoropolymers used in such products, which are defined as polymers with multiple carbon-flourine bonds in it their molecular structure.

Key Provisions

From January 1^st, 2032, the following products containing intentionally added PFAS may no longer be sold or distributed in Illinois:

• Cosmetics, including soaps
• Dental floss
• Juvenile products
• Menstrual products
• Intimate apparel
  
  

Exemptions from the ban

Products exempt from the ban include:

• Medical devices or drugs, as regulated by the FDA
• Used or re-sold items
• Internal electronic components
• Items regulated under federal pesticide law (FIFRA)

IEPA Reporting on Fluoropolymers

The law also directs the Illinois Epa to submit a report by August 1^st, 2027 that covers:

1. The state’s regulatory and administrative readiness to review fluoropolymers in consumer products.
2. Assessment of scientific data and existing regulatory actions on fluoropolymers.
3. Identification of potentially critical uses of fluoropolymers and their supply chain implications.