1. Report Summary
| Review Date | 2026-09-02 (Asia/Shanghai) |
|---|---|
| Key Areas Monitored | EU REACH SVHC Candidate List, US EPA TSCA |
| Major Same-Day Changes | None (no same-day additions or emergency revisions to lists/rules detected) |
| Overall Risk Level | Low–Medium (baseline compliance obligations remain in force; recent key deadlines have passed or are approaching) |
Note: No major same-day changes to EU REACH SVHC or US EPA TSCA were detected on the review date, so this is a daily monitoring report. However, several critical compliance milestones in July–August 2026 have taken effect or are approaching, requiring immediate attention from exporters.
2. EU REACH SVHC (Key Focus)
- Current status: The Candidate List contains 253 entries. The latest update (2026-02-04) added n-hexane (CAS 110-54-3) and 4,4′-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol and its salts (BPAF, Bisphenol AF).
- Key deadline: For articles containing a newly listed SVHC above 0.1% (w/w), manufacturers/importers must notify ECHA within six months of inclusion (i.e., by 2026-08-04) under REACH Art. 7(2); SCIP database notification under the Waste Framework Directive also applies.
- Risk alert: The notification deadline (Aug 4) has passed. Exporters to the EU who have not yet notified are in a state of non-compliance, facing Member State enforcement, product recalls, and market exclusion.
Recommended Actions:
- Immediately screen the supply chain to confirm whether articles contain n-hexane / BPAF (focus: fluoroelastomer seals/O-rings, cleaning agents, coatings, cross-linking agents).
- For articles above 0.1% with annual volume above 1 tonne, submit the overdue ECHA notification promptly and complete the SCIP notification in parallel.
- Establish a semi-annual SVHC review mechanism (ECHA typically updates the list every six months; a new update is expected in H2 2026).
- For fluoroelastomer parts containing BPAF, assess the future risk of inclusion in the Authorisation List (Annex XIV) and identify substitute materials early.
3. US EPA TSCA (Key Focus)
- 2026-07-30 (Proposed Rule): EPA proposed Significant New Use Rules (SNURs) for 14 chemicals previously subject to PMNs, covering few-layer graphene materials, photoresist sulfonates, tert-butylalanine for semiconductor manufacturing, electronic/nanomaterials, etc. Once finalized, a 90-day advance notification before manufacture (incl. import) or processing will be required.
- 2026-07-23 (Final Rule): EPA extended compliance dates for the perchloroethylene (PCE) and carbon tetrachloride (CTC) risk management rules without weakening substantive protections.
- 2026-04 (Final Rule): The TSCA section 8(a)(7) PFAS reporting start date was delayed to 2027-01-31 (or 60 days after the revised final rule takes effect, whichever is earlier), giving entities that manufactured/imported PFAS in 2011–2022 more preparation time.
- 2026-05-22 (Final Rule): The TSCA 8(d) health and safety data reporting deadline was extended to 2027-05-21.
Risk Level: Low–Medium (mostly extensions and proposals, not immediate bans).
Recommended Actions:
- PFAS-related entities: use the extended window to compile 2011–2022 PFAS manufacture/import data and prepare reporting materials.
- Exporters of the 14 SNUR-proposed substances: assess whether products fall under a “significant new use” and submit comments during the comment period if needed.
- Continuously track PMN/SNUR final rules and build an internal 90-day advance-notification workflow.
4. China GB Standards (Baseline)
- 2026-07-30: 15 mandatory national standards released (incl. GB 7916-2026 Cosmetics Safety General Requirements).
- 2026-05-25: Two mandatory PV standards (Safety Requirements for PV Modules; Nameplate Marking Requirements for PV Modules) released, effective 2027-06-01.
- 2026-08-01: GB 46520-2025 Safety Specifications for Burning Behaviour of Thermal Insulation Materials implemented.
- No same-day additions.
5. Overall Action Plan (by priority)
- Priority 1 (Urgent): Screen supply chains and complete overdue EU REACH SVHC notifications (n-hexane / BPAF).
- Priority 2 (Monitor): Track the 14-chemical TSCA SNUR proposal comment process and PFAS reporting preparation.
- Priority 3 (Baseline): Monitor GB mandatory standard effective dates and align domestic production accordingly.
Sources: ECHA, US EPA / Federal Register, SAMR/SAC public announcements. For reference only; consult official texts for compliance.
发表回复