Plain-English notes on every Candidate List update, the PFAS restriction and the rules that touch SME manufacturers and importers, written by a materials and product-compliance engineer, not a marketing team.
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Last checked: 12 October 2026
Commission Regulation (EU) 2026/859 adds entry 83 to Annex XVII. From 11 May 2027, articles for professional users or the general public may not be placed on the market if they contain 2,4-DNT (CAS 121-14-2) at 0.1% by weight or more. Explosives, military and police ammunition, toys, medical devices and food-contact articles are exempt, and seat-belt and bonnet gas generators in vehicles follow from 11 May 2029.
What to do: Check rubber, plastic and propellant-containing parts with your suppliers and plan substitution before May 2027.
Read the official text (opens in a new tab)The updated Community Rolling Action Plan schedules 17 substances for evaluation by Member States in 2026, with concerns ranging from reproductive toxicity and endocrine disruption to persistence and mobility. A CoRAP listing is not a restriction, but it often comes before one.
What to do: If a listed substance is in your products, ask your supplier about its regulatory outlook now.
Two new entries trigger Article 33 and SCIP duties for articles above 0.1% by weight. Solvents, adhesives and fluoropolymer supply chains are most exposed.
What to do: Re-screen products that use solvents or fluoropolymers and update your Article 33 communications.
Read the official text (opens in a new tab) Our full noteDelegated Directives (EU) 2025/1802, 2025/2363 and 2025/2364 replace the broad lead exemptions 7(a), 7(c) and 6(a) to 6(c) with narrower sub-entries. Several general exemptions end between 11 December 2026 and 30 June 2027, and the new specific ones mostly run to 31 December 2027.
What to do: List every part that relies on a lead exemption and confirm it still fits one of the new sub-entries.
Read the official text (opens in a new tab)Regulation (EU) 2025/1561 moves the battery due diligence obligations from 18 August 2025 to 18 August 2027. The substance restrictions on mercury, cadmium and lead in batteries are unchanged and still apply.
What to do: Keep screening batteries for mercury, cadmium and lead; use the extra time to set up supply chain due diligence.
Read the official text (opens in a new tab)Two entries added. Article 33 and SCIP duties now apply to articles containing either substance above 0.1 % w/w. Solvent-based adhesives, cleaning products and fluoropolymer supply chains are most exposed.
Read the update →RAC's opinion and SEAC's draft opinion were published on 26 March 2026; the consultation closed on 25 May. SEAC's final opinion is expected around the end of 2026, then the Commission drafts the restriction. Time-limited derogations, not indefinite exemptions, are the direction of travel.
Coming soonThe 0.1 % w/w rule, why it is calculated per article and not per product, the "once an article, always an article" principle, and what a compliant communication must contain.
Coming soonWhere the composition table hides in multi-part sheets, why ranges are given, what to do when the EC column is missing, and how Verachek reads the same table.
Coming soonAnnex III and IV, expiry dates, how to tell whether your product category qualifies, and why "homogeneous material" is the phrase that decides most cases.
Coming soonIf you import a product with a battery inside, Regulation (EU) 2023/1542 applies to you. The substance limits, labelling and what the battery passport will ask for.
Coming soonScreen the product against all 13 lists, free.
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