Policy Monitoring Daily | 2026-07-12 | New Materials Export Compliance

Policy Monitoring Daily | July 12, 2026 (Sunday)

Scope: EU REACH SVHC / US EPA TSCA / China GB Standards

Major change today: None published (Sunday, no official updates)

1. US EPA TSCA — PFAS Reporting Rule (Section 8(a)(7)) ⚠️ HIGH PRIORITY / IMMEDIATE ACTION

Key date: The reporting deadline for small businesses that ONLY handle imported articles containing PFAS was July 11, 2026 (closed yesterday).

Impact: Companies that produced/imported PFAS or PFAS-containing articles since Jan 1, 2011 and failed to submit data (manufacture, use, disposal, exposure, environmental hazards) via the CDX system by the deadline are now in “late-filing” status, facing a compliance gap and potential enforcement risk.

Recommended actions:

• Immediately verify whether you are subject to TSCA 8(a)(7) reporting obligations.
• If triggered but not yet filed, submit as soon as possible, retain submission proof, and assess whether proactive communication with EPA is warranted to mitigate penalties.
• Exporters of fluoropolymers, fluorinated coatings, firefighting foams, non-stick coatings, and fluorinated textiles to the US should prioritize screening.

2. China GB Standards — GB38031-2025 “Safety Requirements for Power Batteries of Electric Vehicles” 🔴 IN FORCE (July 1, 2026)

Key date: Mandatory national standard, effective July 1, 2026 for newly type-approved vehicle models (existing approved models transition until July 2027).

Impact: Hailed as the “strictest battery safety standard ever.” Core upgrade: thermal propagation test raised from “5-minute alarm” to a mandatory “no fire, no explosion” requirement; new bottom-impact test (150J steel-ball impact, no leakage/fire/explosion) and post-fast-charge safety test (external short-circuit pass after 300 fast-charge cycles).

Recommended actions:

• Battery and material suppliers (cathode, separator, electrolyte, thermal-management materials) should verify products meet the new thermal-runaway protection requirements.
• Exporters of battery packs and materials to the EU/US should prepare conformance documentation and test reports aligned with the new standard.
• Anticipate surging testing/certification demand — single bottom-impact test cost exceeds RMB 2 million.

3. EU REACH SVHC Candidate List — 253 entries (updated Feb 2026) 🟡 ONGOING OBLIGATIONS

Baseline: 33rd update published Feb 4, 2026, adding n-Hexane and BPAF (4,4′-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]bisphenol) and its salts, totaling 253 entries. No additions in the recent (June) round.

Impact: Articles with SVHC >0.1%(w/w) trigger REACH Art. 33 communication duties; >0.1% AND >1 t/y exports require Art. 7 notification to ECHA; SCIP database notification under WFD is also required.

Recommended actions: Maintain supply-chain substance declarations (SCSD); add BPAF and n-Hexane to your new-substance screening list; anticipate the next update (typically June/December).

Risk Level

Medium — No new policy today, but high-priority compliance nodes have just closed or taken effect.

Consolidated Recommendations

• Immediate: Address TSCA PFAS late filing (if applicable).
• This week: Complete GB38031-2025 conformance self-check and schedule testing.
• Ongoing: Maintain REACH SVHC supply-chain screening and SCIP notifications.