1. Monitoring Overview
| Item | Detail |
|---|---|
| Review date | September 5, 2026 (Saturday) |
| Key areas monitored | EU REACH SVHC Candidate List; US EPA TSCA Significant New Use Rules (SNUR) |
| Same-day major change | None (no same-day additions or emergency revisions to lists/rules detected) |
| Overall risk level | Medium — baseline compliance obligations in force; near-term effective dates require attention |
2. EU REACH SVHC Candidate List (Baseline Monitoring)
- Current status: The Candidate List contains 253 entries (36th update). The latest update, on 2026-02-04, added n-Hexane (CAS 110-54-3) and Bisphenol AF and its salts (BPAF, substance group).
- Critical compliance milestone (PASSED): For articles containing the newly listed SVHCs at ≥0.1% (w/w), the ECHA notification deadline under REACH Art.7(2) was six months after listing — i.e., 2026-08-04. That deadline has passed; exporters who have not notified are now non-compliant, facing Member State enforcement, product recalls, and market-access risk.
- Ongoing obligations: Supply-chain communication (Art.33, including free written replies to consumers within 45 days); SCIP database notification under the Waste Framework Directive; possible future inclusion in the Authorisation List (Annex XIV).
- Update cadence: ECHA typically updates the list around January and July; a H2 2026 update is expected around October. A semi-annual review mechanism is recommended.
3. US EPA TSCA (Significant New Use Rules – SNUR)
| Action | Date | Key point |
|---|---|---|
| Multi-walled Carbon Nanotube (MWCNT) SNUR final rule | Effective 2026-09-22 (~17 days away) | PMN P-22-163, used as an additive in battery manufacturing; establish a 90-day advance-notification (SNUN) workflow before effectiveness |
| SNUR final rule (24-5.5e, batch) | Published 2026-08-26 / Effective 2026-10-26 | For substances previously under PMNs and TSCA 5(e) Orders, any use deviating from Order restrictions is a “significant new use” requiring 90-day advance notice |
| 14-substance SNUR proposed rule (26-4) | Comment period closed 2026-08-31 | Covers few-layer graphene, photoresist sulfonates, tert-butylalanine (semiconductor mfg.), etc.; awaiting final rule |
| PCE/CTC compliance-date extension final rule | Effective 2026-07-28 | Perchloroethylene and carbon tetrachloride risk-management compliance dates extended to 2027 (no weakening of protections) |
4. Risk Level Summary
| Policy area | Risk level | Affected parties | Trigger |
|---|---|---|---|
| EU REACH SVHC (BPAF / n-Hexane) | Medium-High | Exporters of fluoroelastomers, elastomers, cleaners, coatings, electronic components to the EU | In force; notification deadline 2026-08-04 passed |
| US TSCA SNUR (MWCNT / 24-5.5e / 14-substance proposal) | Medium | Exporters of nanomaterials, electronic/semiconductor materials to the US | MWCNT effective 2026-09-22; 24-5.5e effective 2026-10-26 |
5. Recommended Actions (for Chinese Exporters)
- Immediately (within 7 days): Screen EU-bound articles for n-Hexane and BPAF, focusing on fluoroelastomer seals/O-rings, cleaning agents, coatings, and cross-linking agents.
- For articles containing the above substances at ≥0.1% with annual volume ≥1 tonne, submit the overdue ECHA notification and complete the SCIP database notification in parallel.
- Carbon-nanotube / nanomaterial exporters: Confirm the MWCNT SNUR effective date (2026-09-22), build a 90-day advance-notification (SNUN) workflow, and submit via EPA Form 7710-25 / e-PMN software.
- Semiconductor / electronic chemical exporters: Assess whether any “significant new use” is triggered; track final-rule progress on 24-5.5e and 26-4.
- Establish a standing tracking mechanism: TSCA new-chemical PMN/SNUR tracking + semi-annual REACH SVHC review.
6. Baseline Information Record
- SVHC Candidate List: 253 entries (as of 2026-02-04).
- Pending substance: Resorcinol (1 entry).
- Key EPA dates: MWCNT SNUR effective 2026-09-22; SNUR 24-5.5e effective 2026-10-26; PCE/CTC extended to 2027; TSCA 8(d) health & safety data reporting deadline extended to 2027-05-21.
- Conclusion: No major same-day policy change. This is a daily monitoring report recording baseline status and near-term effective dates for enterprise scheduling.
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