Chemicals | Monthly bulletin | October 2026

Europe

EU Adds Chlorpyrifos to Persistent Organic Pollutants List

On the 10^th of September 2026, the European Commission has adopted Commission Delegated Regulation (EU) 2026/1423, amending Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs) to formally include chlorpyrifos among substances subject to strict EU prohibitions and controls.

A significant feature of the new regulation is the establishment of a stringent limit for unintentional trace contamination. The regulation sets a maximum concentration of 0.01 mg/kg (0.000001% by weight) for chlorpyrifos when present unintentionally in substances, mixtures, or articles. This measure is intended to strengthen enforcement and ensure a high level of protection for human health and the environment.

The Commission stated that the amendment aligns EU legislation with international commitments under both the Stockholm Convention and the Protocol on Persistent Organic Pollutants under the Convention on Long-Range Transboundary Air Pollution.

The regulation entered into force on the 30^th of September 2026.

Updated EU POPs Rules for Long-Chain PFCAs and Medium-Chain Chlorinated Paraffins

In September 2026, the European Commission adopted two delegated regulations amending Annex I of Regulation (EU) 2019/1021 on persistent organic pollutants (POPs), further aligning EU legislation with recent decisions taken under the Stockholm Convention. 

On the 7^th of September 2026, the Commission adopted a delegated regulation adding long-chain perfluorocarboxylic acids (LC‑PFCAs), their salts and related compounds. Long-chain PFCAs belong to the broader PFAS family of chemicals and have been used in a range of industrial applications due to their resistance to heat, water and oil. 

Some specific exemptions for intermediate use or other specifications apply where:

• C9–C21 PFCAs and their salts present as unintentional trace contaminants (UTC) in substances, mixtures, or articles, with a total concentration ≤ 0.025 mg/kg;
• C9–C21 PFCA-related compounds present as unintentional trace contaminants in substances, mixtures, or articles, with a total concentration ≤ 0.26 mg/kg.

Consult the complete list in the annex of the adopted delegated regulation here.

A second delegated regulation, adopted on the 11^th of September 2026, adds medium-chain chlorinated paraffins (MCCPs). MCCPs are used in a variety of industrial applications, including lubricants, metal-working fluids, adhesives, sealants and other specialty products. 

• The sum of concentrations of the linear C14–C17 chloroalkanes of the following molecular formulae: C14H(30−y)Cly where y ≥ 5; C15H(32−y)Cly where y ≥ 5; C16H(34−y)Cly where y ≥ 6; C17H(36−y)Cly where y ≥ 6 equal to or below 1000 mg/kg (0,1 % by weight) where they are present in substances, mixtures or articles.
• The sum of concentrations of the linear C14–C17 chloroalkanes of the following molecular formulae: C14H(30−y)Cly where y ≥ 5; C15H(32−y)Cly where y ≥ 5; C16H(34−y)Cly where y ≥ 6; C17H(36−y)Cly where y ≥ 6 equal to or below 20000 mg/kg (2 % by weight) where:
  • they are present in recovered material from cable recycling or in articles produced with such material, and
  • the material or articles in EN 2 EN which they are present are used in road furniture or in blocks to support fences.

This limit value shall apply until the 16^th of December 2028.

Consult the complete list of specific exemptions in the annex of the adopted delegated regulation here.

Following their adoption by the European Commission, the delegated regulations on long-chain PFCAs and MCCPs are undergoing scrutiny by the European Parliament and the Council. If no objections are raised, the measures will be published in the Official Journal of the European Union and will enter into force 20 days later, implementing the Stockholm Convention decisions within EU law.

European Commission Prepares New Performance and Durability Requirements for Portable Batteries

The European Commission launched preparations for a new delegated regulation that will establish mandatory minimum performance and durability requirements for portable batteries of general use sold in the European Union. The initiative forms part of the implementation of the EU Battery Regulation and is currently under development, with adoption planned for the second quarter of 2027.

According to the Commission, the future rules will apply to portable batteries of general use, excluding button cells, and will set mandatory minimum values for electrochemical performance and durability parameters. The objective is to ensure that batteries placed on the EU market deliver adequate performance throughout their expected lifetime and meet minimum quality standards.

The initiative is currently at the preparation stage and a draft delegated act is expected before adoption. The Commission has indicated that the delegated regulation is planned for adoption in the second quarter of 2027.

US 

California enacts new restrictions on bisphenols in paper receipts

On September 30^th, 2026, California Governor Gavin Newsom signed Assembly Bill 1604 (Chapter 882, Statutes of 2026), establishing new restrictions on bisphenol A (BPA) and other bisphenols in paper receipts. The legislation adds Chapter 12.3 (commencing with Section 108943) to the California Health and Safety Code and introduces a phased prohibition on intentionally added bisphenols in paper proofs of purchase. 

The law aims to reduce exposure to bisphenols commonly used in thermal receipt paper, including BPA and bisphenol S (BPS), which may present potential health concerns for consumers and workers who frequently handle receipts.

Scope and key requirements

The legislation applies to paper receipts issued at the point of sale for purchases of food, alcoholic beverages, other tangible personal property, or services.

Under the new law, businesses must comply with the following restrictions:

The law defines bisphenols as chemicals containing two phenol rings connected by a single linker atom, including compounds with additional substituents on the phenol rings or linker atom.

Requirements for chemical substitutions

In addition to restricting bisphenols, AB 1604 establishes requirements for manufacturers replacing these substances in receipt paper.

Manufacturers must use the least toxic alternative and are prohibited from substituting bisphenols with chemicals identified by the U.S. Environmental Protection Agency or California as causing, or having specified evidence of, cancer, reproductive toxicity, or developmental harm

Enforcement and penalties

The California Department of Toxic Substances Control (DTSC) is authorised to adopt implementing regulations and enforce the requirements.

Violations may result in administrative penalties of up to $5,000 for a first violation and $10,000 for each subsequent violation. DTSC must also publish substantiated violations and final enforcement actions on its website. 

The new restrictions will affect manufacturers and suppliers of receipt paper, as well as retailers and other businesses involved in distributing or using paper receipts in California. Businesses should review their receipt paper formulations and supplier documentation to prepare for the upcoming compliance deadlines.

Connecticut Expands Approved PFAS Labeling Options for Consumer Products

The Connecticut Department of Energy and Environmental Protection (DEEP) has expanded its list of approved labelling statements and symbols for consumer products containing intentionally added per- and polyfluoroalkyl substances (PFAS). The update provides manufacturers with additional options to comply with the state's PFAS labelling requirements under Connecticut General Statutes § 22a-903c, established through Public Act 24-59.

Since July 1^st, 2026, Connecticut has required specified consumer products containing intentionally added PFAS to carry labels informing purchasers of their presence. The requirements apply to 12 product categories, including apparel, carpets and rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, juvenile products, menstruation products, textile furnishings, ski wax, and upholstered furniture. 

Expanded labelling options

DEEP has approved additional labeling statements, including:

• "This product contains PFAS"
• "Contains PFAS in internal components"
• "Contains PFAS in packaging components"
• A chemical disclosure statement beginning with "This product contains:", followed by a list of chemicals that includes "PFAS" or "PFAS chemicals"

In addition, manufacturers may use two approved symbols featuring an Erlenmeyer flask containing the letters "PFAS," either with or without an exclamation mark.

These alternatives supplement previously approved statements, including "Contains PFAS," "Made with PFAS," "Made with PFAS chemicals," "Made with intentionally added PFAS," and "This product contains PFAS chemicals."

DEEP may also approve alternative labelling language or symbols upon petition by a manufacturer or producer.

Labelling requirements

Regardless of the wording or symbol selected, labels must be clearly visible before sale and inform consumers that PFAS are present. Labels affixed to products must be sufficiently durable to remain legible throughout the product's useful life.

The expanded labelling options do not change the existing notification requirements or upcoming restrictions on intentionally added PFAS.

Upcoming restrictions

Beginning January 1^st, 2028, Connecticut will prohibit the manufacture, sale, offer for sale, and distribution of specified products containing intentionally added PFAS, subject to applicable statutory exemptions. The prohibition covers the 12 product categories identified above, as well as outdoor apparel for severe wet conditions and firefighting turnout gear.

Manufacturers and other businesses supplying products to Connecticut should review their existing PFAS disclosures and ensure compliance with applicable labelling, notification, and future prohibition requirements.

New Jersey Bans Intentionally Added PFAS in Apparel and Diaper Products

On August 27^th , 2026, the state of New Jersey signed S1281 into law as P.L.2026, c.76, amending New Jersey's 2025 "Protecting Against Forever Chemicals Act" (P.L.2025, c.202) to add apparel and diaper products as newly covered categories. The base 2025 Act already regulates intentionally added PFAS in carpets, cosmetics, fabric treatments, plant-fiber derived food packaging, and cookware.

Scope

The law creates two separate covered-product categories:

• Apparel — clothing items intended for regular wear or formal occasions, defined broadly to include undergarments, shirts, pants, skirts, dresses, overalls, bodysuits, vests, dancewear, suits, tops, leggings, school uniforms, athletic wear, sports uniforms, everyday swimwear, formal wear, onesies, footwear, and everyday work-wear, plus outdoor apparel (including apparel designed for severe wet conditions).
• Diaper products — absorbent products, disposable or reusable, manufactured to be worn to contain human waste. Menstrual products are excluded from this definition (diapers were carved out of the "apparel" definition and given their own category during the Assembly committee substitute process.)

Key obligations

• Prohibition: No person may sell, offer for sale, manufacture, or distribute for sale or use in New Jersey any apparel or diaper product containing intentionally added PFAS.
• "Intentionally added PFAS" is defined as PFAS added to a product, or intentionally used during development of a product or a product component, to provide a specific characteristic, appearance, or quality, or to perform a specific function — including known degradation byproducts. The definition excludes technically unavoidable trace PFAS stemming from impurities in natural or synthetic ingredients or from the manufacturing process.
• Manufacturer certification: Manufacturers must certify, in a form and manner to be prescribed by the New Jersey Division of Consumer Affairs (NJDCA), that each apparel or diaper product they manufacture does not contain intentionally added PFAS. Certifications are valid for five years and must be updated if manufacturing processes or materials change. Manufacturers must provide certification copies to purchasers.
• "Manufacturer" is defined to include the entity whose brand name is affixed to the product. For imported products, the importer or first domestic distributor is deemed the manufacturer if the actual manufacturer/brand owner has no U.S. presence.

Effective dates

• The act took effect immediately upon signing (August 27^th , 2026).
• The sales/manufacture/distribution prohibition and the certification requirement take effect two years later, on August 27^th , 2028.
• The Division of Consumer Affairs is authorised to adopt implementing regulations and will prescribe the form and manner of the required certification. Companies should monitor future NJDCA guidance or rulemaking concerning implementation of the certification requirement.

Exemptions / Carve-Outs

• Product exclusions: Personal protective equipment; clothing exclusively for U.S. military use; and equipment/protective apparel designed for safe motorcycle or off-highway-vehicle operation.
• Media liability: The law does not impose liability on news media that accept or publish advertisements for otherwise regulated products.

Enforcement

A violation of this section constitutes a violation of the underlying Protecting Against Forever Chemicals Act (P.L.2025, c.202), triggering that act's existing remedies and penalties. Under that framework, NJDCA may impose civil administrative penalties in the range of $1,000–$20,000 per violation per day; penalties pursued through the courts can reach up to $25,000 per day.

New Mexico issues guidance on mandatory PFAS labelling for consumer products

The New Mexico Environment Department (NMED) has published guidance to assist manufacturers and other businesses in complying with the state's labeling requirements for consumer products containing intentionally added per- and polyfluoroalkyl substances (PFAS).

The guidance, issued in July 2026, supports implementation of New Mexico's PFAS Protection Act (House Bill 212, enacted in 2025) and its implementing regulations under 20.13.2 NMAC. The regulations establish phased restrictions, reporting obligations, and labelling requirements for consumer products containing intentionally added PFAS.

PFAS labelling requirements

Beginning January 1^st, 2027, consumer products manufactured on or after this date and containing intentionally added PFAS must carry a label identifying the presence of these substances, unless a specific exemption or approved waiver applies. The requirement also covers finished products containing components with intentionally added PFAS.

The mandatory label must feature an Erlenmeyer flask symbol with the letters "PFAS" displayed inside the flask. The label must be clearly visible and legible to consumers before purchase.

NMED's guidance provides clarification on several aspects of labelling compliance, including:

• Product and packaging labels: Labels must be displayed on products and, where packaging prevents the product label from being visible before purchase, on the packaging. Special provisions apply to products too small to accommodate a legible label.
• Label size and appearance: The PFAS lettering must be no smaller than the largest font used for other consumer information on the product or packaging. No specific label colour is mandated.
• Online and catalog sales: PFAS disclosures must be included in online product listings and other sales materials when consumers cannot view the product or packaging label before purchase.
• Complex durable goods: The guidance provides examples of labelling through product specifications, manuals, and other consumer-facing documentation.
• Alternative labelling: Manufacturers may seek NMED approval to use PFAS labels adopted in other states, subject to applicable conditions.

Exemptions and labelling waivers

Certain product categories are exempt from the labelling requirements, including specified federally regulated products such as medical devices and drugs and certain pesticide products.

Manufacturers may also request a labelling waiver for eligible products where intentionally added PFAS are confined to internal components that do not come into contact with consumers during intended use, provided the applicable regulatory conditions are satisfied.

Importantly, products containing fluoropolymers may be exempt from PFAS reporting requirements and sales prohibitions but remain subject to labelling obligations.

Upcoming Compliance Deadlines

Manufacturers, importers, and retailers supplying products to New Mexico should review the composition of their products, identify any intentionally added PFAS, and evaluate applicable labelling, reporting, and prohibition requirements before the relevant compliance deadlines.

International

Review of new flame retardants and advancing global PFAS discussions under POP legislation

The twenty-second meeting of the Persistent Organic Pollutants Review Committee (POPRC.22) was held in Rome, Italy, from the 21^st of to the 25^th of September 2026 under the Stockholm Convention on Persistent Organic Pollutants.

Key discussions focused on two flame retardants proposed for listing under the Convention: decabromodiphenylethane (DBDPE) and bis(2-ethylhexyl) tetrabromophthalate (TBPH). The Committee also continued its assessment of brominated and mixed brominated/chlorinated dioxins and furans.

PFAS remained high on the agenda, with reviews of existing exemptions for PFOS-related substances and updates to indicative lists covering PFOA, PFHxS, and long-chain PFCAs. These discussions support the ongoing implementation of global PFAS controls.

Other technical discussions addressed persistent organic pollutants present in stockpiles, products, articles in use, and waste streams. Committee members also explored ways to improve the submission of Annex F information and reviewed activities related to the global monitoring plan for newly listed POPs.