1. PFAS: EU-wide restriction continues to take shape
The planned universal PFAS restriction under REACH has undergone key procedural steps in 2026. The Committee for Risk Assessment (RAC) adopted its opinion in March; the Committee for Socio-Economic Analysis (SEAC) has also submitted its draft. ECHA generally supports a comprehensive PFAS restriction but provides for targeted exemptions for certain applications.
2. PPWR: PFAS Limit Values Applicable as of August 12, 2026
The new EU Packaging Regulation (PPWR) – Regulation (EU) 2025/40 – has generally been in effect since August 12, 2026. Of particular relevance to material compliance: as of this date, food contact packaging may no longer exceed certain PFAS limits. Among other things, the limits are set at 25 ppb for individual, specifically analyzed PFAS and 250 ppb for the total of certain PFAS. The European Commission has also published guidance on practical testing. Important: For packaging placed on the market after August 12, 2026, there is generally no grace period for previously produced, non-compliant packaging. The European Commission clarified the interpretation of the PPWR by publishing a new FAQ in August 2026.
Transition Period for National Penalty Provisions
However, pursuant to Article 68 of the PPWR, Member States have until February 12, 2027, to establish national penalty provisions for violations of the regulation and to notify the European Commission thereof. This does not, however, entail a general suspension of the PPWR requirements or of regulatory enforcement until that date.
3. RoHS: New Rules for Lead Exemptions
There are also specific changes regarding RoHS exemptions. Delegated Directive (EU) 2025/2364 has, among other things, revised the exemptions for lead as an alloying element in steel, aluminum, and copper. For example, the previous exemption 6a for lead in steel expires on December 11, 2026, while the revised sub-exemptions apply in some cases until June 30, 2027.
For more information, please visit:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025L2364
4. REACH: Market Surveillance Shifts Focus More Toward Products
Pressure is also mounting in the area of enforcement. In June 2026, the ECHA Enforcement Forum decided that the next EU-wide enforcement project will focus on REACH restrictions on hazardous substances in products. Online sales are also to be included in the inspections. Previous findings already demonstrate the relevance of these inspections: During an EU-wide inspection of imports, issues such as missing REACH registrations and prohibited substances or substances present in excessive concentrations in consumer products were identified.
Additional information is available at:
https://echa.europa.eu/es/-/inspectors-to-check-compliance-with-restrictions-on-hazardous-substances-in-products
