The postponement forms part of the EU’s broader effort to simplify regulatory burdens, reduce costs, and strengthen competitiveness — a key message of the Commission’s “One-in, One-out” agenda for industry.

What Has Changed

1. Extended Deadlines

Most revised CLP requirements — including re-labelling, harmonised formatting, distance-sales disclosures, advertising rules, and fuel-pump labelling — will now apply from 2028.
This delay gives companies more time to:

• Re-engineer label templates and safety-data workflows

• Update chemical inventories and supplier declarations

• Budget for packaging redesigns and translation updates

For SMEs, this means breathing room — but also a longer transition to manage dual systems (old vs. new labels) through 2027.

2. Simplification and Cost Relief

The reform is packaged under “Omnibus VI,” which the Parliament says could save European industry around €363 million per year.
Simplification measures include:

• Clearer hazard-label formatting for easier comprehension and reduced translation cost

• Alignment of cosmetics and fertiliser rules with REACH and CLP, reducing duplicated data submissions

• Consolidated information requirements for mixtures and online sales

In short: less administrative friction, more coherence across product sectors.

3. Legal Certainty — Fast

To prevent uncertainty for manufacturers planning 2026–2027 portfolios, Parliament applied an urgency procedure.
This fast-tracks adoption so that both industry and regulators know the new timeline well in advance.
Formal Council approval is still required, but since the Council already endorsed the same text in September, final sign-off is expected shortly.

What This Means for Compliance Managers

The two-year extension is not a pause — it’s a strategic window. Use it to strengthen systems, not to delay preparation.

These would be your recommended next steps:

• Re-align Implementation Roadmaps

• Revise your internal CLP compliance roadmap to reflect the 2028 date.

• Adjust procurement and packaging contracts to include the new labelling obligations.

• Update supplier communication templates with revised information-sharing requirements.

• Optimise Resources and Training

Don’t underestimate the cost-saving opportunities embedded in Omnibus VI: fewer redundant labels, harmonised data fields, and unified submission formats across sectors.
The delay allows early adopters to build cross-compliance efficiencies linking CLP, REACH, and product-specific regimes.

Monitor Final Adoption and Guidance

Keep an eye on the Council’s formal approval and the subsequent publication in the Official Journal of the EU.
Expect the Commission and ECHA to issue updated guidance and transitional FAQs once the law is adopted.

Strategic Takeaway

The CLP reform delay is good news for preparedness — not an excuse for inaction.
By 2028, the EU expects every market operator to speak the same “labelling language” across sectors and sales channels.
Companies that use this buffer period to digitise documentation, clean up supply-chain data, and train teams will enter 2028 with a competitive advantage.

• Regulations database + Library (See LabTools)

• Product Safety Alerts and Recall notifications database.

Stay tuned for more.

The new application date would be 30 December 2026 for most operators and traders.

What is the EUDR?

The EUDR requires operators and traders to conduct due diligence. You must demonstrate that goods are deforestation-free. You must also prove they comply with laws in the country of production.

The regulation covers these commodities:

• Cattle

• Cocoa

• Coffee

• Palm oil

• Rubber

• Soy

• Wood

It also covers a broad set of derived products (for example paper and stationary and products that include wooden elements).

The first delay

On 2 October 2024, the Commission proposed a one-year delay. Stakeholders needed more time to prepare. This moved the application date to 30 December 2025.

Simplification efforts

There are growing calls to simplify the EUDR. The Commission is reviewing EU sustainability and environmental rules. It launched a call for evidence in July 2025 on simplification proposals. This closed on 10 September 2025.

Companies and NGOs are watching closely. They want to know if the EUDR will be simplified as part of this delay.

What happens next?

The Commission will table a "stop the clock" proposal. This would delay application by one year. The European Council and Parliament must approve it before it takes effect.

The current deadline is 30 December 2025. Time is running short.

Possible simplifications

Watch for signals about further EUDR changes. These might include:

• Reduced administrative requirements

• Adjustments to the country and region risk benchmarking timeline

• Practical changes to the EUDR Information System

What this means for you

If you manage compliance across multiple markets, this delay provides breathing space. Use it to prepare your due diligence systems.

If you work in product management or engineering, you need to understand how EUDR affects your supply chain. The delay gives you more time to implement changes.

Keep an eye on the Updates-section for news about simplification proposals. These could reduce your compliance burden.

The Delegated Regulation applies to spectacles (lenses and frames) and ready-to-wear reading glasses. It introduces the requirement for manufacturers to assign a Unique Device Identifier ('UDI-DI'), or Master UDI-DI. The requirements enter into force on 1 November 2028. Manufacturers are allowed to already assign it before that date.

The Commission is currently developing a guidance document Medical Device Coordination Group (MDCG). It is expected to be ready for publication by November 2025.

The text of the Delegated Regulation 2025/1920 is enclosed below:

More information about the UDI-DI is available at the European Commission's website.

Source: https://eur-lex.europa.eu/eli/reg_del/2025/1920/oj

https://spectrumlocalnews.com/nys/central-ny/news/2025/09/22/researchers-discover-pfas-eating-bacteria--

Source: Spectrum New 1.

What's changed?

The European Parliament has adopted sweeping amendments to the Waste Framework Directive that introduce mandatory EPR schemes for textiles across all 27 EU member states. The new law covers clothing, footwear, accessories, hats, blankets, bed linen, kitchen textiles, and curtains – essentially anything fabric-based that enters the European market.

The directive targets ultra-fast fashion practices, giving member states the power to set higher EPR fees for brands producing short-lived, difficult-to-recycle garments. Meanwhile, companies investing in durability and circular design could benefit from reduced costs under the scheme.

This represents a fundamental shift from taxpayer-funded waste management to a "polluter pays" system that makes producers directly accountable for their products' entire lifecycle.  How is this going to affect prices? Most likely, the cost of new fashion items will increase significantly; however, this will lead to a decrease in consumption, prompting consumers to turn to sustainable, reusable, and long-lasting products. Compliant products. 

Currently, Europe generates a staggering 12.6 million tonnes of textile waste annually – that's 12 kg per person every year just from clothing and footwear. With less than 1% of textiles globally recycled into new products, the current system is clearly broken.

The legislation deliberately puts fast fashion in the firing line. Member states can now structure EPR fees to penalise high-volume, low-quality business models whilst rewarding sustainable practices.

You might be wondering if you will be affected? It is relatively simple; if you find yourself in the following five categories, then you should work on your strategy.

Fashion brands and manufacturers: No matter how you write your brand on the label, if you sell textiles in the EU, you're in scope. This includes all clothing, accessories, and household textiles.

E-commerce platforms: Online marketplaces – including non-EU platforms like Shein or Temu – must comply equally with European brands—no exemptions for digital-first businesses. 

Importers and distributors: Anyone placing textile products on the EU market bears EPR responsibility, regardless of where the products are manufactured.

Small businesses: Micro-enterprises get an extra year to comply, but they're not exempt. Start planning now for implementation in 2028.

Mattress manufacturers: Member states may extend EPR schemes to mattresses, signalling potential expansion into other high-waste categories.

So if you found yourself here, here are the risks you're facing right now:

• EPR fees will directly impact your bottom line, calculated based on waste management expenses

• Brands that can't prove sustainable practices may face higher fees or operational restrictions

• Companies that are slow to adapt could lose market position to more circular competitors

• Non-compliance with EPR schemes could trigger fines or market access restrictions

What to do now?

Start by auditing your current textile portfolio to understand EPR exposure across product categories and calculate potential compliance costs based on volume and product types. Identify which EU markets you operate in and track their EPR scheme development.

Develop sustainable design strategies that could reduce EPR fees and engage with industry associations and EPR scheme operators in key markets. Update product development processes to consider end-of-life recyclability and train compliance teams on new textile waste responsibilities.

Before the schemes go live, you'll need to register with EPR schemes in each EU member state where you operate, implement data collection systems for waste management reporting, and establish financial provisions for ongoing EPR contributions.

What's coming next?

October 2025: The directive enters into force following publication in the EU Official Journal

June 2027: Member states must transpose the rules into national law (20-month deadline)

April 2028: All EPR schemes must be operational (30-month deadline from entry into force)

April 2029: Micro-enterprises must comply (additional 12-month grace period)

Each member state will design its own EPR scheme, meaning compliance requirements may vary between countries. However, the core principle remains consistent: producers pay for their waste.

" As the EPR regime is now limited to several products (electrical and electronic equipment, batteries, packaging and packaging waste), the EU plans to expand it to other product categories gradually. The textile industry and food industry can already start thinking about how their business will be impacted by the regulations, and orienting on implementation. And it's best to start now.” — Product Compliance Lab Legal Team

Need Help Preparing for Textile EPR?

Whether you need to assess your compliance exposure, develop circular design strategies, or navigate EPR registration across multiple EU markets, our team specialises in making complex regulations actionable.

👉 Book a 20-minute strategy call with our compliance experts

Further Reading & Resources

• European Parliament Press Release on New Textile Waste Rules

• European Commission Revision of Waste Framework Directive

What the Commission found

The Report on Controls on Products Entering the EU Market provides the first three-year analysis of product compliance enforcement under Regulation (EU) 2019/1020. The data paints a concerning picture of uneven protection across the single market.

In 2024, customs authorities across the EU conducted 392,529 interventions on products entering from third countries. These controls resulted in 244,470 suspensions and ultimately led to 64,322 refusals for non-compliant or dangerous products. Whilst absolute numbers increased each year from 2022 to 2024, relative performance tells a different story.

The control rate dropped from 203 interventions per million released items in 2022 to just 82 per million in 2024. The discovery rate—products actually refused entry—fell from 20 per million to 13 per million over the same period.

The report exposes massive enforcement disparities between member states. The best-performing country refused 175 items per million imports, whilst the worst managed just 0.1 refusals per million—a staggering 1,750-fold difference.

Three member states essentially operate open borders for product compliance, conducting fewer than five interventions per million items released. Meanwhile, two countries exceed EU averages by more than tenfold, creating a patchwork of protection levels across the single market.

Products from China dominated refusals (48,139 items), followed by the United States (3,427) and the United Kingdom (2,120).

Health products topped the category list with 30,995 refusals, followed by home and living items (14,505) and electronics (9,404).

Why this matters for your business

Non-compliant products circulating freely within the single market increase product liability risks. A defective electrical appliance that injures someone creates legal exposure regardless of where it entered the EU. The Commission explicitly warns that underperforming member states face "further actions" to improve enforcement. Thus, you can surely expect tighter controls, higher penalties, and more stringent requirements as authorities scramble to address gaps.

With 94% of refused products facing strict refusal rather than modification opportunities, prevention becomes critical. Build compliance verification into supplier contracts and shipping procedures.

What is coming next

The Commission's Communication on e-commerce strategy adopted February 2025 signals intensive action on low-value imports. Expect coordinated controls between customs and market surveillance authorities targeting specific operators, goods, and trade flows.

The proposed EU Customs Reform introduces game-changing elements, including an EU Customs Authority, centralised risk management, and expanded platform responsibilities. Parliament adopted its position in March 2024, with Council agreement reached in June 2025. Implementation discussions now focus on operational details and timelines.

Member states using the December 2025 electronic interface for notifications gain competitive advantages through automated reporting and better coordination with market surveillance authorities. Those maintaining manual systems face increased administrative burdens and potentially stricter oversight.

Need help navigating these changes? Our Product Compliance Lab offers practical guidance to manufacturers, importers, and retailers navigating evolving EU requirements. 

Book a consultation to discuss your specific compliance strategy.

• Safety of Thimerosal (CAS No. 54-64-8, EC No. 200-210-4) and Phenylmercuric salts as preservatives in cosmetic products
  The deadline is 22 January 2025.

• Cannabidiol (CBD) (CAS/EC No. 13956-29- 1/ 689-176-3) used in cosmetic products
  The deadline is 22 January 2025.

• Prostaglandin analogues ‘Ethyl Tafluprostamide’ (DDDE) (CAS No. 1185851-52-8, EC No. 867-521-0), Methylamido-Dihydro-Noralfaprostal (MDN) (CAS No. 155206-01-2, EC No.-) and Isopropyl Cloprostenate (IPCP) (CAS No. 157283-66-4, EC No.-)
  The deadline is 27 March 2024.

Requesting this scientific research means that these substances are now on the radar of the EU regulatory authorities and that measures may be expected.

Stay tuned.

On 19 July 2025, the world's first universal framework for digital product passports debuted in Beijing, developed by the Zhongguancun Industry and Information Research Institute of Two-dimensional Code Technology and international partners. This isn't just a technical milestone — it's a strategic move that could reshape how manufacturers prove product compliance across global markets and how digital product passports (DPPs) will work internationally.

What China has built

The MA-DPP Universal Framework V1.0 provides foundational services and public infrastructure for digital product passports. Unlike isolated national systems, China's framework offers:

Unified technical foundation

• Standardised identifier rules to solve data interconnection challenges

• Compatible data exchange protocols across different systems

• Open APIs enabling low-code development for third parties

Strategic market positioning. The Chinese DPP system is designed to address three critical "customs questions" in the product trade process: What you are (product identification), Who you are (manufacturer verification), and Whether you can pass customs (compliance with standards).

Industry-ready implementation. Initial pilots are already underway to develop China's DPP system for batteries. The Chinese battery ID ecosystem was launched on 1 January 2025, covering the entire supply chain from raw materials to final production.

Why this matters for EU compliance

The timing is no coincidence. From 18 February 2027, all industrial and electric vehicle batteries must include a Battery Passport under EU law. China's framework launch positions Chinese manufacturers to meet these requirements — potentially more efficiently than their global competitors.

Market access implications

China's move creates two possible scenarios for EU market access:

Scenario 1: Mutual recognition. CAICT proposes that China should negotiate with the European Union a principle of mutual recognition between the EU DPP system and China's DPP system. If successful, this would mean Chinese DPPs could be accepted for EU market access, potentially streamlining compliance for Chinese exporters.

Scenario 2: Parallel systems. Without mutual recognition, manufacturers may need to maintain separate DPP systems for different markets, increasing complexity and costs.

Timeline of competing developments

China's aggressive rollout

• January 2025: Battery ID ecosystem operational

• July 2025: Universal framework launched

• 2025-2026: Industry platform development accelerates

EU's steady implementation

• July 2024: ESPR regulation enters force

• February 2027: Mandatory Battery Passport implementation begins

• 2026-2030: DPP requirements for chemical products will be delivered via delegated acts

• End 2025: Commission to establish specific DPP requirements

Will you be affected?

Strategic implications for your business

The competitive dimension

China's digital product passport market is expected to reach USD 2,624.6 million by 2030, growing at a 27.7% CAGR from 2025. This rapid domestic expansion gives Chinese companies significant experience implementing DPP systems before EU requirements become mandatory.

Technical standardisation challenges

Globally, the development of digital product passports has faced challenges, including difficulties in data interconnection due to a lack of standardised identifier rules, incompatible formats, and the absence of unified exchange protocols. China's framework claims to solve these issues, but only if other systems adopt compatible standards.

First-mover advantage

Chinese manufacturers using the universal framework will have two years of operational experience before EU Battery Passports become mandatory. This operational advantage could translate into lower compliance costs and faster market entry.

"China's universal framework represents a fundamental shift from fragmented national approaches to DPP development. Companies that don't consider how Chinese DPP capabilities might affect their competitive position — whether through supply chain integration or direct competition — risk being blindsided by more efficient compliance pathways." — Product Compliance Lab Strategic Team

Looking at the bigger picture

China's universal framework launch signals that DPP development is accelerating beyond EU timelines. The framework will serve as an open international public good, providing standardised solutions for global supply chain digital transformation.

For compliance professionals, this creates both opportunity and complexity. Early engagement with DPP standards — whether EU-focused or internationally compatible — becomes a strategic imperative rather than a simple compliance checklist item.

Ready to navigate the DPP landscape strategically?

Our team monitors both EU DPP requirements and international framework developments. We can help you assess your competitive exposure, plan for multiple compliance scenarios, and position your business advantageously as these systems develop.

👉 Schedule a 20-minute call to discuss how Chinese framework developments might affect your EU market access strategy.

Further reading and official sources

• European Commission ESPR Regulation

• EU Digital Product Passport Information

• China Academy of Information and Communications Technology (CAICT)

• International Identification Code Industry Alliance

On 8 July 2025, the European Commission published its Chemicals Industry Action Plan (CIAP), setting out a roadmap for a more sustainable, competitive, and resilient EU chemicals sector. This isn't just another regulatory update. It's a complete transformation of how chemical compliance works, with new obligations, simplified procedures, and stricter enforcement coming into effect from Q3 2025 through 2026.

The Commission estimates that at least €363 million in annual savings can be achieved through simplification measures alone. However, new obligations for polymer registration and digital reporting will require upfront investment in systems and processes.

Regardless of where you sell within the European Union, these changes will directly impact your operations, costs, and market access across all 27 Member States.

Four major reforms are changing the game, so let’s dive in

1. Product compliance overhaul

   The  Sixth Simplification Omnibus has already been adopted, bringing immediate changes to the Classification, Labelling and Packaging (CLP) Regulation. The updates span regulations on chemical labelling (CLP), cosmetics, fertilisers, and support broader goals of decarbonisation and the circular economy.

CLP Regulation changes include:

• Streamlined formatting and labelling rules with exemptions for font sizes and packaging requirements

• Introduction of digital contact points on product labels

• Simplified hazard communication for advertisements and distance sales

• Label update flexibility: Removes the fixed 6-month deadline for label updates; now required "without undue delay"

2. REACH regulation targeted revision

   The ongoing revision of the REACH Regulation aims to modernise processes in light of safety, security and sustainability aspects, with the final version of the legislation expected in Q4 of 2025.

The REACH changes include:

• Registration validity will now be limited to 10 years, and ECHA will be able to revoke registration numbers for failure to submit updates or incomplete data

• Polymer registration requirements: Notification will be required for all EU-manufactured or imported polymers above 1 tonne per year – both PRR and non-PRR

• Extension of the Generic Risk Approach to Persistent, Mobile, and Toxic (PMT) substances and endocrine disruptors

• Introduction of digital data safety sheets aligned with Digital Product Passport requirements

3. PFAS phase-out strategy

   Following the comprehensive PFAS restriction proposal by national authorities in 2023, the Commission will pursue a dual approach: reducing PFAS use and mitigating risks, while supporting the development of industrial-scale safe alternatives. The phased evaluation process highlights the complexity of regulating PFAS, substances found in a wide variety of applications from consumer goods to industrial processes.

4. Enhanced market surveillance

   The newly introduced Import Surveillance Task Force, operational since March 2025, is responsible for monitoring potential trade diversions, i.e., harmful foreign trade practices such as price dumping. The Commission is also considering establishing a centralised EU Market Surveillance Authority to complement existing national authorities.

How it progressed and what will change

Q3 2025: The import surveillance of chemicals through the Import Surveillance Task Force was strengthened, and the new ECHA Basic Regulation proposal was presented

REACH Proposal - COM_2025_531_1_EN_ACT_part1_v4.pdf

Q4 2025:

• Implementing act under the Single-Use Plastic Directive for chemical recycling tracking

• Critical Chemicals Alliance establishment

• Harmonised, risk-based controls to ensure imported chemicals comply with EU regulations

2026:

• Circular Economy Act (planned for 2026)

• PFAS Committee opinions expected from ECHA

• Full REACH revision implementation begins

Will you be affected?

What do you need to do now?

Taking the right actions at the right time can save you a lot of resources. Acting strategically now can reduce compliance costs, streamline operations across the EU, and position your business advantageously for the post-2026 regulatory landscape. 

Premium members can download our EU Chemicals Action Plan 2025 Checklist from the "Templates and Checklists" section.

Why early preparation matters

The industry's pursuit of decarbonisation while safeguarding competitiveness remains non-negotiable. The Chemical Action Plan represents a fundamental shift toward harmonised EU-wide compliance, digitalisation, sustainability and stricter enforcement

"This is the biggest regulatory overhaul the EU chemicals sector has seen since REACH was introduced in 2007. Companies that start preparing now — particularly for polymer notification requirements and digital compliance systems — will avoid the costly last-minute scrambles that typically follow major regulatory changes." — Product Compliance Lab Legal Team

Ready to prepare your compliance strategy?

Our team is already helping clients map their chemical portfolios, assess PFAS exposure, and prepare for the new polymer notification requirements. We can guide you through the regulatory maze and help you turn these changes into competitive advantages.

👉 Download the EU Chemicals Action Plan 2025 Checklist from the "Templates and Checklists" section.

👉 Schedule a 20-minute Chemical Action Plan consultation with our compliance experts to discuss your specific situation and develop an action plan tailored to your needs.

Further reading and official sources

• European Commission Chemical Action Plan

• European Chemicals Agency (ECHA)

• REACH Regulation Information

• Classification, Labelling and Packaging (CLP) Regulation