April 2026

On 9 April 2026, the U.S. Environmental Protection Agency finalized a change to the start of the reporting period under the TSCA section 8(a)(7) PFAS reporting rule. The reporting start date has been moved from 13 April 2026, to 60 days following the effective date of EPA's forthcoming revision to the PFAS 8(a)(7) rule. This delay provides the EPA with additional time to review thousands of public comments submitted in response to the November 2025 proposed updates, with a final revised rule expected later in 2026.

On 9 April 2026, the United States Environmental Protection Agency (EPA) announced the finalization of a revised start date for the Toxic Substances Control Act (TSCA) section 8(a)(7) per- and polyfluoroalkyl substances (PFAS) reporting period. The original start date of 13 April 2026 has been postponed. Reporting will now commence 60 days after the effective date of EPA's forthcoming revision to the PFAS 8(a)(7) rule.

Background: TSCA section 8(a)(7) requires any person that has manufactured (including imported) PFAS in any year between 2011 and 2022 to report the following information to the EPA: chemical identity; uses; volumes manufactured and processed; byproducts; environmental and health effects; worker exposure; and disposal methods.

Reason for Delay: EPA is currently reviewing thousands of public comments received regarding the November 2025 proposed updates to the PFAS 8(a)(7) rule. The delay is intended to allow the agency to refine the rule to deliver clearer, more actionable reporting guidance, and to close potential loopholes that could delay health-protective decisions.

Next Steps: EPA plans to issue a final revised rule later in 2026. The EPA's guidance and reporting tool will be made available to help ensure collected data are complete, accessible, and useful to regulators, communities, and researchers.

On 30 March 2026, the European Commission published a draft guidance document and a Frequently Asked Questions (FAQ) listing for Regulation (EU) 2025/40 on packaging and packaging waste . These documents provide critical interpretative details for the restriction on PFAS in food contact packaging.

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), published in the Official Journal of the European Union on 22 January 2025, will take effect on 12 August 2026. On 30 March 2026, a newly created draft guidance document and a Frequently Asked Questions (FAQ) listing corresponding to this regulation were published to provide the following key clarifications:

1. Scope of Application:

The restriction applies to the entire packaging unit, including all components such as inks, varnishes, glues, and adhesives.

2. Intentional vs. Unintentional:

The limit applies to all perfluoroalkyl and polyfluoroalkyl substances (PFAS) present, making no distinction between intentionally added substances and those unintentionally present (e.g., from recycled materials or contamination).

3. Market Placement Rules:

• All food contact packaging placed on the market on or after 12 August 2026, must comply with the PFAS restriction.

• Packaging placed on the market before 12 August 2026 may continue to be sold without recall. There is no stock depletion transition period for non-compliant inventory produced before that date.

• Packaging containing recycled materials is also subject to the restriction.

4. Recommended Testing Scheme:

Due to the absence of a unified European Union (EU) method, a three-step testing approach is recommended to demonstrate compliance:

• Step 1 (Total Fluorine Test): If total fluorine is < 50 mg/kg, the sample is considered compliant.

• Step 2 (Organic Fluorine Test): If total fluorine is ≥ 50 mg/kg, an organic fluorine test (e.g., by GC/MS) is performed. If organic fluorine is < 50 mg/kg, the sample is considered compliant.

• Step 3 (Targeted Analysis): If steps 1 and 2 indicate potential PFAS presence, targeted analysis (e.g., Precursor) is used to check compliance with the specific concentration limits of 25 μg/kg (ppb) for any individual PFAS and 250 μg/kg (ppb) for the sum of PFAS.

5. Future Review:

The Commission will evaluate whether this PPWR restriction needs amendment or repeal if it overlaps with restrictions under other EU laws like the Food Contact Materials Regulation, registration, evaluation, authorization and restriction of chemicals (REACH), or the persistent organic pollutants (POPs) Regulation.

Impact & Recommendations:

This guidance is critical for all economic operators supplying food contact packaging to the EU. With the compliance deadline approaching, businesses are advised to:

- Conduct a comprehensive formula screening of all packaging components to avoid using PFAS.

- Use total fluorine < 50 mg/kg as a safety threshold for initial compliance verification.

- Perform deep supply chain traceability, with particular focus on high-risk areas such as recycled materials and oil-resistant coatings, to secure compliance documentation from suppliers.

On 13 March 2026, the Hong Kong Government published in the Gazette the Toys and Children's Products Safety Ordinance (Amendment of Schedules 1 and 2) Notice 2026. The Notice seeks to update the safety standards for toys and four classes of children's products listed in Schedule 2 (Schedule 2 products) under the Toys and Children's Products Safety Ordinance (Cap. 424)

The Hong Kong Government issued amendment notice 2026 to the Toys and Children’s Products Safety Ordinance (Cap. 424) (Schedules 1 and 2) on 13 March 2026, which was published in the Gazette. The last updates to Schedules 1 and 2 were implemented in August 2025.

The Ordinance stipulates that a person must not manufacture, import or supply a toy or an associated Schedule 2 product unless it complies with all the applicable requirements contained in any one of the safety standards (international standards or standards adopted by major economies) specified in Schedule 1 or Schedule 2.

Schedule 1 is applicable to toys.

Schedule 2 products include the following four classes:

1. children's high chairs and multipurpose high chairs for domestic use

2. children's paints

3. playpens for domestic use

4. wheeled child conveyances

The Notice will take effect on 1 August 2026.

Amendments are as follows:

(A) Schedule 1 amended (toy standards)

(1) Schedule 1, item 2(c)—

Repeal “BS EN 71-3:2019 + A1:2021”, Substitute “BS EN 71-3:2019 + A2:2024”.

(2) Schedule 1, item 2(d)—

Repeal “BS EN 71-4:2020”, Substitute “BS EN 71-4:2020 + A1:2025”.

(3) Schedule 1, item 2(hab)—

Repeal “BS EN 71-13:2021 + A1:2022”, Substitute “BS EN 71-13:2021 + A2:2024”.

(B) Schedule 2 amended (Schedule 2 product standards)

(1) Schedule 2, item 8, column 2—

Repeal “BS EN 14988:2017 + A1:2020” , Substitute “BS EN 14988:2017 + A2:2024”.

(2) Schedule 2, item 8, column 2—

Repeal “(a) ISO 9221-1:2015 “Furniture—Children’s high chairs—Part 1: Safety requirements”, and (b) ISO 9221-2:2015 “Furniture—Children’s high chairs—Part 2: Test methods””, Substitute “ISO 9221:2024“Furniture—Children’s high chairs—Safety requirements and test methods””.

(3) Schedule 2, item 9, column 2—

Repeal “BS EN 71-3:2019 + A1:2021”, Substitute “BS EN 71-3:2019 + A2:2024”.

(4) Schedule 2, item 11, column 2—

Repeal “ASTM F406-22” Substitute “ASTM F406-24”.

(5) Schedule 2, item 12, column 2—

Repeal “AS 2088:2022” Substitute “AS 2088:2022 (incorporating Amendment 1:2024)”.