分类： Policy Compliance

Report date: Monday, 24 August 2026　|　Sources monitored: EU REACH / EU PPWR, US EPA TSCA, China mandatory GB standards & new-substance environmental management　|　Overall risk level: 🟠 Medium-High

1. Bottom line first

1. No new rule broke today, but two mandatory changes took effect earlier this month and both are in their earliest enforcement window: the EU Packaging and Packaging Waste Regulation (PPWR), fully applicable from 12 August, and China’s closure of the “environmental management filing” route for new chemical substances from 15 August. Both apply immediately, with no transitional relief.
2. No formal REACH SVHC update today. The Candidate List remains at 253 entries (last formal update 4 February 2026). The REACH Article 7(2) notification deadline for the two newly listed substances — n-hexane and bisphenol AF (BPAF) — expired on 4 August 2026. EU/EEA producers and importers of articles that were in scope but did not notify are now in breach and should remediate immediately.
3. Disinformation alert (key item this issue): at least six articles circulated this month claiming ECHA added 3 / 5 / 12 / 5 / 13 SVHCs on 4, 7, 8, 9 and 13 August respectively. These claims contradict each other, cite no ECHA source, and are assessed as false. Do not initiate reformulation, issue customer declarations, or revise conformity documentation on the basis of them.

Risk snapshot

#	Policy area	Item	Status	Risk
1	EU PPWR (EU) 2025/40	Substance limits + PFAS limits + EU DoC + EPR now fully applicable	In force 2026-08-12	🔴 High
2	China new chemical substances	Filing (“备案”) route discontinued; registration application required instead	In force 2026-08-15	🟠 Medium-High
3	EU REACH SVHC	Article 7(2) notification deadline for n-hexane / BPAF expired	Expired 2026-08-04	🟡 Medium (remediation)
4	China mandatory GB standards	Announcement No. 34/2026 (15 mandatory GBs); 2 material-related GBs effective 1 Aug	Issued / partly in force	🟡 Medium
5	Information environment	Fabricated “August ECHA SVHC additions” circulating widely	Ongoing this month	🟠 Medium-High (decision risk)

2. Major changes and alerts

Alert 1 | 🔴 High: EU PPWR (EU) 2025/40 fully applicable since 12 August 2026

Effective: 12 August 2026 (day 12)　|　Legal status: a Regulation — directly applicable in all 27 Member States plus Northern Ireland, no national transposition required. Directive 94/62/EC is repealed.

Obligations that applied immediately from 12 August:

Article	Requirement	Scope
Art. 5 — heavy metals	Sum of lead + cadmium + mercury + hexavalent chromium ≤ 100 mg/kg	All materials and all packaging components, including inks, adhesives, coatings and labels
Art. 5(5) — PFAS	Any individual non-polymeric PFAS < 25 ppb; sum of targeted non-polymeric PFAS < 250 ppb; total fluorine including polymeric PFAS < 50 ppm. Where total fluorine exceeds 50 mg/kg, evidence of the fluorine origin (PFAS vs non-PFAS) must be available on request	Food-contact packaging as a whole; covers both intentionally added PFAS and non-intentional presence (NIAS)
Art. 5(1) — substances of concern (SoC)	Presence and concentration of SoC must be minimised and demonstrable. The Commission and ECHA are expected to publish an SoC list before 31 December 2026 (likely anchored on the REACH SVHC list)	All packaging
Arts. 38/39 — conformity	Manufacturer performs conformity assessment, compiles technical documentation and issues an EU Declaration of Conformity. Retention: 5 years (single-use), 10 years (reusable). Must be produced within 10 working days of a competent authority request	Every packaging type
Arts. 15/18 — identification	Model / batch / serial number plus manufacturer (and, where applicable, importer) name and address, on the packaging or in accompanying documents	All packaging
Art. 44 — EPR	Registration required separately in each Member State of first placing; registration numbers are not transferable between countries. Non-EU companies need an EU authorised representative	All producers placing packaged goods on the market
Art. 6 — recyclability	Packaging must be recyclable and a declaration provided. Design-for-recycling grade gates (≥ C from 1 Jan 2030; ≥ B from 1 Jan 2038) restrict market access only from those dates	All packaging

Enforcement details that are easy to miss:

• There is no stock-exhaustion period. The Commission has confirmed that packaging manufactured before 12 August 2026 but first placed on the EU market after that date must comply. Packaging already placed on the market before 12 August may remain. Goods in transit and finished-goods inventory are therefore the sharpest near-term exposure.
• Testing must be layer-by-layer. Cartons, folding boxes and laminates must be separated into substrate, ink, lamination film and adhesive and tested individually. Averaging across mixed materials is not acceptable, and different materials — or the same material in different colours — cannot be combined into a single test.
• No harmonised EU PFAS test method yet. The Commission guidance of 5 June 2026 recommends a stepwise approach: (1) measure total fluorine — below 50 mg/kg per kg of packaging may be considered compliant; (2) where total fluorine is exceeded, distinguish organic from inorganic fluorine (e.g. pyrolysis-GC/MS) — organic fluorine below 50 mg/kg may be considered compliant; (3) use direct TOP (total oxidisable precursor) analysis to verify the 25 µg/kg and 250 µg/kg limits.
• Responsibility cannot be contracted away. Conformity assessment may be delegated to a third-party laboratory, but the duty to compile technical documentation and to issue the DoC rests with the manufacturer. A food-contact DoC under Regulation (EU) No 10/2011 may be merged into a single document with the PPWR DoC, but the two conformity assessments must be completed separately.

Impact on the advanced-materials value chain:

• Barrier coatings and functional additives are hit hardest. Traditional fluorinated barrier systems — side-chain fluoropolymers, fluorinated processing aids — are effectively unusable in food-contact grease-proof paper, paper straw coatings, moulded-pulp tableware, microwaveable packaging and flexible laminates. Migration paths point to fluorine-free systems: waterborne acrylic and polyolefin extrusion coatings, modified starch, PVOH, bio-based waxes and fluorine-free sizing agents.
• Non-intentional presence is now a live risk. The limits do not distinguish intentional from unintentional PFAS. Trace fluorine carried in via recycled fibre, shared equipment, release agents or upstream masterbatch counts. The Commission has indicated early lab data suggests only intentionally treated packaging exceeds the limits, but rising recycled content erodes that margin.
• Inks, adhesives and coatings are pulled into the heavy-metals chain. 100 mg/kg is a sum of four metals and applies to every component. Pigments (particularly yellow, red and orange systems), metallised layers and closure lacquers are the recurring exceedances.
• Data transparency requirements step up. To issue a DoC, brand owners will push full material disclosure and test data upstream. Material suppliers need a workable balance between formulation confidentiality and disclosure — typically third-party confidential disclosure, or a substance declaration plus CAS-level screening conclusions.

Recommended actions:

1. This week: freeze and inventory EU-bound packaging that is produced but not yet placed on the market. Split by placing date into “placed before 12 Aug” (may continue to circulate; retain placing records) and “placed after 12 Aug” (must comply) and screen the latter for total fluorine plus the four heavy metals.
2. This week: confirm your own role under PPWR (manufacturer / importer / authorised representative). Do not assume the customer carries the duty — the DoC obligation follows whoever places the packaging under their own name and controls the design specification.
3. Within 2 weeks: build a “total-fluorine-first” three-step test plan across all EU-bound food-contact SKUs. Use total fluorine as a low-cost triage gate and reserve organic-fluorine and TOP analysis for samples above 50 mg/kg to control testing spend.
4. Within 2 weeks: verify EPR registration country by country (Germany, France, Italy, Spain, Belgium, Netherlands, Ireland, Poland and Sweden are the practical priorities). No registration means no market access.
5. Within 1 month: issue a PPWR-specific supplier questionnaire (sum of four heavy metals, total fluorine, whether any fluorinated treatment is used, recycled content share, SoC self-assessment) and add regulatory-change notification and non-compliance liability clauses to purchase contracts.
6. Ongoing: track the SoC list and the recycled-content calculation methodology expected before 31 December 2026. Both will shape technical roadmaps for 2028–2030.

Alert 2 | 🟠 Medium-High: China closed the new-substance “environmental management filing” route on 15 August 2026

Instrument: Notice of the General Office of the Ministry of Ecology and Environment (MEE) on matters concerning environmental management registration of new chemical substances (issued 31 July 2026, published early August)　|　Effective: 15 August 2026 (day 9)

What changed:

• From 15 August 2026, MEE no longer processes environmental management filings for new chemical substances.
• Entities that previously qualified for the filing route under the Measures for Environmental Management Registration of New Chemical Substances (MEE Order No. 12) must now, before manufacture or import, submit a registration application form together with evidence supporting the applicable circumstance under Article 10(3) of the Measures, plus any hazard and environmental-risk information already available.
• The authority accepts and reviews these submissions by reference to the simplified registration procedure and its timelines.
• Legislative driver: implementation of the Ecological and Environmental Code of the PRC. The Notice lapses automatically once MEE issues new rules on new-substance registration.

Impact analysis:

• Most exposed: introduction projects for new monomers, new additives, new polymers and new electronic chemicals that previously relied on the filing route (small annual volumes, polymers, R&D and export-only scenarios).
• From notification to approval — timing risk increases. Filing was essentially a notification step; registration, even under a simplified procedure, involves acceptance, review and statutory timelines. New-product introduction and first-import schedules must be re-planned, with buffer built into the R&D–pilot–commercial sequence.
• Documentation burden rises. Applicants must supply both the Article 10(3) evidence and available hazard/risk information, increasing dependence on data cooperation from non-Chinese upstream suppliers.
• Transitional treatment is unclear. The Notice does not state how filings completed before 15 August will be treated, nor how in-flight applications are handled.

Recommended actions:

1. This week: inventory all new substances in development or introduction, flag those planned for the filing route, and rebuild each dossier as a registration application. For submissions already lodged but not concluded, confirm handling with MEE’s Solid Waste and Chemicals Management Technology Centre.
2. This week: archive all filing confirmations obtained before 15 August (number, date, substance identity) as evidence supporting the legality of existing manufacture and import.
3. Within 2 weeks: request hazard and environmental-risk data packages from overseas suppliers (physico-chemical, degradation, bioaccumulation, ecotoxicity, human-health endpoints) to close registration data gaps.
4. Ongoing: monitor MEE’s forthcoming new-substance rules under the Ecological and Environmental Code — the current Notice lapses automatically when they are issued, so the rules may change again.

Alert 3 | 🟡 Medium (remediation phase): REACH Article 7(2) notification deadline for n-hexane and BPAF expired on 4 August 2026

Background: on 4 February 2026 ECHA (press release ECHA/NR/26/06) added two substances to the SVHC Candidate List, taking the total from 251 to 253 entries:

Substance	EC / CAS	Reason for inclusion	Typical uses
n-hexane	203-777-6 / 110-54-3	Art. 57(f) — specific target organ toxicity after repeated exposure (neurotoxicity)	Cleaning agents, coatings, inks, adhesives; solvent in formulation and polymer processing
4,4′-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol and its salts (bisphenol AF, BPAF)	— / —	Art. 57(c) — toxic for reproduction	Process regulator, cross-linking agent; fluoroelastomers, high-performance resins, electronic chemicals

Bisphenol F (BPF, 4,4′-dihydroxydiphenylmethane), assessed in the same batch, was withdrawn and not listed. Resorcinol remains pending.

The expired obligation: REACH Article 7(2) requires EU/EEA producers and importers of articles to notify ECHA where the substance is present above 0.1 % (w/w) and in quantities exceeding 1 tonne per producer or importer per year, within six months of inclusion — i.e. by 4 August 2026. That deadline passed 20 days ago.

Why this one gets missed: n-hexane is the first SVHC listed on a non-CMR basis (STOT-RE). Many screening templates are still built around CMR and PBT triggers and simply do not catch it. The BPAF entry covers “and its salts”, so it functions as a substance family rather than a single CAS, making bill-of-materials screening materially harder. Fluoroelastomer seals, high-performance resins and electronic chemicals are the primary exposure.

Recommended actions:

1. Immediately: confirm whether the Article 7(2) trigger applies (> 0.1 % and > 1 t/a). If it applies and no notification was filed, submit now and document the internal timeline. Lateness does not extinguish the obligation, and voluntary correction is materially better than being found in an inspection.
2. Immediately: confirm the continuing duties are being met: Article 33 supply-chain communication (triggered at > 0.1 %; consumer requests answered within 45 days), SCIP database notification under the Waste Framework Directive, and safety data sheet updates for substances and mixtures. These have no end date and are permanent compliance items.
3. Within 2 weeks: extend SVHC screening templates to cover non-CMR inclusion routes (Article 57(f) equivalent-level-of-concern) and add a substance-family-plus-salts screening rule for BPAF.
4. Ongoing: the Candidate List is normally updated once or twice a year, historically in January–February and June–July. No formal update occurred in June 2026, so the next window is expected in January–February 2027.

Alert 4 | 🟡 Medium: new batch of Chinese mandatory GB standards; two material-related mandatory GBs took effect on 1 August

(1) National Standard Announcement No. 34 of 2026 (approved 30 July 2026): 15 mandatory GB standards. Items relevant to advanced materials and chemicals:

Standard	Title	Supersedes	Effective
GB 14569.1-2026	Performance requirements for low-level radioactive waste forms — cement solidified forms	GB 14569.1-2011	2026-09-01
GB 17411-2026	Marine fuel oils	GB 17411-2015	2027-02-01
GB 15578-2026	Resistance welding machines — safety requirements	GB 15578-2008	2027-02-01
GB 44721-2026	Intelligent connected vehicles — safety requirements for automated driving systems	GB/T 44721-2024	2027-07-01
GB 1787-2026	Aviation piston engine fuels	GB 1787-2018	2027-08-01
GB 18047-2026	Compressed natural gas for vehicles	GB 18047-2017	2027-08-01
GB 25199-2026	Biodiesel blended automotive diesel fuel	GB 25199-2017	2027-08-01
GB 7916-2026	Cosmetics — general safety requirements	GB 7916-1987	2028-01-01

(2) On 11 August 2026, SAMR approved 338 national standards (15 mandatory, 323 voluntary). Points of interest for advanced materials: 38 materials standards covering wrought superalloys, composite rolls, and epoxy-coated steel wire and strand, aimed at localisation of critical materials and expansion into high-end applications; new-display standards for stereoscopic and flexible display devices; and optoelectronics standards for optical circuit boards and fibre-optic interconnect components.

(3) Mandatory GB standards that took effect on 1 August 2026 (materials-related):

• GB 46039-2025, Safety technical specification for concrete admixtures (mandatory, first edition, effective 2026-08-01) — admixture producers and users must complete the compliance switch.
• GB 46520-2025, Safety technical specification for burning behaviour of thermal insulation materials and products for buildings (effective 2026-08-01), with the companion GB 8624-2025, Classification for burning behaviour of building materials and products effective 2027-01-01 — the technical requirements and classification logic for insulation materials (EPS/XPS, polyurethane, phenolic, mineral wool) are being upgraded in parallel.

Recommended actions: (a) insulation and concrete-admixture producers should immediately verify that in-production models have completed type testing and label updates under the new mandatory standards — products shipped after 1 August fall under the new rules; (b) fuel producers (marine fuel, CNG, biodiesel blends) should plan specification iteration and test capability against the 2027 dates; (c) obtain the specific numbers and effective dates of the 38 wrought-superalloy and related materials standards and add them to the product standards conformity register.

3. Disinformation check: the “August ECHA SVHC additions” circulating this month are false

This monitoring cycle identified at least six Chinese- and English-language articles claiming that ECHA updated the SVHC Candidate List in August 2026. Their claims contradict each other:

Claimed date	Claimed content	Assessment
2026-08-04	3 new SVHCs (flame retardants, dye intermediates); impact on paper and paper chemicals	❌ No ECHA source
2026-08-07	5 new SVHCs (cosmetic raw materials, baby-care coatings, pet-product plastic additives)	❌ No ECHA source
2026-08-08 / 08-09	12 and 5 new SVHCs (flame retardants, plasticisers, nano metal oxides, organophosphorus); plus a required “EN 14040:2026” declaration	❌ No ECHA source; the cited standard number cannot be verified
2026-08-11	Mandatory SCIP filing for “eco-polymers” from 11 August	❌ No ECHA source
2026-08-13	REACH amendment adding 13 PFAS to the SVHC list with mandatory notification and substitution assessment	❌ No ECHA source

Basis for the assessment: (1) ECHA has historically updated the Candidate List once or twice a year, each time with a numbered press release (for example ECHA/NR/26/06 on 4 February); five updates in a single month has no precedent. (2) The substance counts, categories and effective dates in these articles conflict with one another. (3) All originate from content-farm sites with no official announcement link, no CAS or EC numbers and no regulation reference. (4) The verified Candidate List total remains 253 entries.

Recommended actions:

• Do not act on these claims. An incorrect customer declaration creates its own compliance and reputational exposure.
• Accept only three sources for SVHC changes: the ECHA Candidate List table (echa.europa.eu/candidate-list-table), numbered ECHA press releases, and the Official Journal of the EU. Third-party laboratory bulletins (SGS, CTI, Eurofins and similar) are useful signals but must be traced back to the primary text.
• Add a single-authoritative-source verification step to the compliance SOP: no external regulatory intelligence enters a remediation workflow without an official announcement link or regulation number.

4. Trend tracking (not yet in force, but requiring preparation)

4.1 EU universal PFAS restriction under REACH — decisive point at year end

• Submitted by the national authorities of Denmark, Germany, the Netherlands, Norway and Sweden on 13 January 2023, covering roughly ten thousand-plus PFAS across 22 sub-sectors. It is the broadest restriction proposal in REACH history.
• Process: RAC adopted its final opinion on 2 March 2026, confirming that EU-wide restriction is justified. SEAC agreed its draft opinion on 10 March, published it on 26 March and opened a 60-day consultation that closed on 25 May 2026. ECHA’s 3 June 2026 briefing reported 3,511 comments from more than 3,200 organisations and 250 individuals; 61.6 % came from companies and 25.9 % from industry and trade associations.
• Next steps: SEAC is expected to adopt its final opinion by end-2026. Both opinions then go to the European Commission, which prepares a restriction proposal for discussion and vote in the REACH Committee of Member State representatives, followed by European Parliament and Council scrutiny. Industry expectation is entry into force around 2027–2028, with transition periods from 18 months to 13.5 years depending on sector.
• Key uncertainties: SEAC favours a group-based restriction with use-specific derogations rather than an immediate full ban, but acknowledges persistent data gaps on alternatives, transition timelines and economic impacts. It does not support time-unlimited derogations for active pharmaceutical ingredients, preferring time-limited ones. The eight sectors added in the 2025 proposal update — printing, sealing, machinery, other medical applications, military applications, explosives, technical textiles and broader industrial uses — were not evaluated sector-by-sector, leaving their derogation prospects the most uncertain.
• Recommended actions: (a) build a PFAS inventory at bill-of-materials level, prioritising fluoropolymer and perfluoroelastomer seals, fluorinated coatings, electronics and semiconductor processes, wiring, fluorinated gases and lubricants; (b) prepare derogation evidence by use rather than by sector, since the quality of alternatives evidence drives the outcome; (c) engage through trade associations on the follow-up investigation of the eight unassessed sectors; (d) maintain time-stamped declarations with clear evidence provenance — the goal is audit-ready, not audit-proof.

4.2 US EPA TSCA 8(a)(7) PFAS reporting — third delay moves the window into 2027

• EPA published a final rule in the Federal Register on 13 April 2026 (91 FR 18786) moving the start of the submission period to 31 January 2027, or 60 days after the effective date of a forthcoming final rule on the substantive requirements, whichever is earlier.
• Submission duration is unchanged: six months generally, and twelve months for small manufacturers reporting exclusively as article importers.
• The exemptions proposed on 13 November 2025 — imported articles, de minimis concentrations at or below 0.1 %, byproducts, impurities, non-isolated intermediates and R&D — are not yet finalised and will be resolved in the substantive final rule. EPA has been explicit that the delay adjusts timing only and does not lower expectations on completeness or accuracy.
• Scope still covers more than 1,460 PFAS, for PFAS, PFAS-containing mixtures and PFAS-containing articles manufactured (including imported) between 1 January 2011 and 31 December 2022, under a “known to or reasonably ascertainable” standard.
• Recommended actions: (a) do not pause preparation — report assembly takes months, and the substantive final rule could trigger the clock well before the 31 January 2027 backstop; (b) continue mapping PFAS manufacture and import records back to 2011 with supporting supply-chain evidence; (c) where you intend to rely on a proposed exemption, document the scope assumption and its evidentiary basis so the position can be switched if the exemption is not finalised.

4.3 Two 2026 amendments to REACH Annex XVII (already in force — baseline)

• Regulation (EU) 2026/859 (published 21 April 2026, in force 11 May 2026): new entry 83 to Annex XVII restricting 2,4-dinitrotoluene (2,4-DNT) in articles for professional users and the general public.
• Regulation (EU) 2026/1168 (published 2 June 2026): amends entry 78 on synthetic polymer microparticles (microplastics) — clarifies the derogation for medicinal products and adds an R&D derogation (both retroactive to 17 October 2023), and tightens the derogation for matrix-encapsulated microplastics with effect from 22 June 2028. The latter has medium-term consequences for masterbatch, encapsulated functional fillers and controlled-release carriers.

4.4 Carried-forward watch items pending primary-source verification

The following items originate from earlier reports in this monitoring series and were not re-verified against a primary official source this cycle. They are listed as signals only; trace the official text before acting.

• US EPA final SNUR for multi-walled carbon nanotubes (MWCNTs, PMN P-22-163), reported as published 24 July 2026 and effective 22 September 2026 (battery additive use; workplace protection, exposure monitoring and hazard communication requirements).
• Proposed SNUR batch 26-3 (27 substances) with comments due 24 August 2026 (today); batch 26-4 (14 substances) with comments due 31 August 2026, and a reported TSCA section 12(b) export notification obligation for covered substances from 31 August 2026.
• GB/T 27563-2026, N-methyl-2-pyrrolidone (NMP) for industrial use, reported as issued with effect from 1 December 2026, adding a battery-industrial grade (purity ≥ 99.90 %), tightened moisture limits, mandatory ppb-level testing for a dozen-plus metal ions, and metallic particle impurity indicators.
• GB 30981.1/.2-2025 (limits of hazardous substances in coatings) and GB 18580-2025 (formaldehyde emission limits for wood-based panels), reported as mandatory from 1 June 2026; GB 38031-2025 (safety requirements for traction batteries of electric vehicles) from 1 July 2026, adding thermal-propagation “no fire, no explosion”, bottom-impact and post-fast-charge safety tests. Of these, the GB 38031-2025 date carries the highest confidence.

5. Baseline information

Source	Baseline as at 2026-08-24	Next key milestone
EU REACH SVHC Candidate List	253 entries (updated 2026-02-04; added n-hexane and BPAF; BPF withdrawn; resorcinol pending)	Next formal update expected Jan–Feb 2027
EU REACH Annex XVII	Entry 83 (2,4-DNT) in force since 2026-05-11; entry 78 microplastics derogations amended	Matrix-encapsulated microplastics derogation tightened 2028-06-22
EU universal PFAS restriction	SEAC draft-opinion stage; consultation closed 2026-05-25 (3,511 comments)	SEAC final opinion: end-2026
EU PPWR (EU) 2025/40	Art. 5 substance limits, DoC, identification, EPR and recyclability declaration now mandatory (2026-08-12)	SoC list and recycled-content methodology: before 2026-12-31
US EPA TSCA 8(a)(7)	Submission period starts 2027-01-31, or 60 days after the substantive final rule takes effect, whichever is earlier	Substantive final rule (exemption scope): expected during 2026
China new chemical substances	Filing route closed from 2026-08-15; registration application required, handled by reference to the simplified procedure	Notice lapses when MEE issues new rules under the Ecological and Environmental Code
China mandatory GB standards	Announcement No. 34/2026 (15 mandatory GBs) issued; GB 46039-2025 and GB 46520-2025 effective 2026-08-01	GB 14569.1-2026 (2026-09-01); GB 8624-2025 (2027-01-01)

6. Action list (ordered by deadline)

Priority	Action	Suggested owner	Timing
P0	Inventory EU-bound packaging produced but not yet placed on the market; split by 12 Aug placing date and screen post-12-Aug batches for total fluorine and four heavy metals	Compliance + Logistics + Sales	This week
P0	Verify whether REACH Art. 7(2) notification was triggered; file late notifications now and confirm Art. 33 / SCIP / SDS duties are met	Compliance	Immediately
P0	Re-plan new-substance introductions in China: convert filing dossiers into registration applications; confirm in-flight cases with MEE’s technical centre; archive pre-15-Aug filing records	R&D + Regulatory	This week
P1	Confirm PPWR role and establish per-model technical documentation and EU DoC templates (5/10-year retention; producible within 10 working days)	Compliance + Packaging engineering	2 weeks
P1	Verify EPR registration and EU authorised representative arrangements country by country	Compliance + Legal	2 weeks
P1	Extend SVHC screening to non-CMR inclusion routes (Art. 57(f)) and family-plus-salts rules (BPAF)	Compliance	2 weeks
P1	Verify type testing and labelling updates for insulation and concrete-admixture lines under GB 46520-2025 and GB 46039-2025	Quality + Standardisation	2 weeks
P2	Issue PPWR supplier questionnaire (heavy-metal sum, total fluorine, fluorinated processes, recycled content, SoC self-assessment) and update contract compliance clauses	Procurement + Compliance	1 month
P2	Build BOM-level PFAS inventory and use-based derogation evidence; prepare to engage on the eight unassessed sectors	R&D + Compliance + Association liaison	Before Q4 2026
P2	Compile PFAS manufacture/import records since 2011 and pre-position data and scope assumptions for TSCA 8(a)(7)	Compliance + Supply chain	Before Q4 2026
P3	Add a single-authoritative-source verification gate to the compliance SOP to block content-farm rumours from entering remediation workflows	Compliance system owner	1 month

7. Method and next monitoring focus

Verification hierarchy used this cycle: primary sources (ECHA press releases and Candidate List, EPA website and Federal Register pre-publication documents, Official Journal of the EU, SAMR announcements, MEE technical centre notices) > established third parties (SGS, Eurofins, CTI, MOFCOM WTO/FTA notification service, Food Packaging Forum) > professional analysis (law firms and consultancies). Content-farm sites are excluded entirely.

Next monitoring focus:

1. Divergence in first-month PPWR enforcement across Member States — particularly acceptance of PFAS test methods and customs sampling practice — and progress on the SoC delegated act.
2. ECHA SEAC final opinion on the universal PFAS restriction (end-2026) and the treatment of the eight unassessed sectors.
3. EPA’s substantive TSCA 8(a)(7) final rule — whether the imported-articles exemption survives will determine whether most non-US article importers are in scope at all.
4. MEE’s new-substance management rules under the Ecological and Environmental Code.
5. Specific numbers and effective dates of the 38 wrought-superalloy and related materials standards within the 11 August 2026 batch of 338 GB standards.
6. The next formal REACH Candidate List update window (expected January–February 2027), with particular attention to the bisphenol family (BPF) and resorcinol.

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Prepared by the Market Intelligence desk from publicly available sources. For all expired and in-force items, verify against the official text before taking legal or commercial action. Items marked as pending verification do not constitute a compliance conclusion.