mars 2026

Rhode Island, Maryland, New York and Ohio introduced bills to expand or establish prohibitions on the manufacture and sale of consumer products containing intentionally added per- and polyfluoroalkyl substances. The proposals introduce requirements for manufacturer registration, disclosure, and product testing. These actions aim to reduce public and environmental exposure to these chemicals, creating new compliance obligations for manufacturers and distributors selling covered products in these states.

To reduce public and environmental exposure to certain harmful chemicals in the United States, the states of Rhode Island, Maryland, New York and Ohio introduced bills to expand or establish prohibitions on the manufacture and sale of consumer products containing intentionally added per- and polyfluoroalkyl substances (PFAS). Please find the analysis of these proposed PFAS Restrictions in Consumer Products as follows:

1. Product-specific Bans

2. Reporting, Registration & Disclosure Requirements

3. Common Exemptions

All proposed bills generally include the following exemptions (with varying specifics):

• Used products offered for sale or resale.

• “Currently unavoidable use”: A use determined by the state agency to be essential for health, safety, or the functioning of society and for which alternatives are not reasonably available.

• Specific products: e.g., certain firefighting foam, PFAS used in industrial manufacturing processes.

4. Core Insights:

• Diverse Legislative Models: States are moving from specific product bans (RI, MD for some) to bans + mandatory reporting (OH), and toward broader concentration-based bans + supply chain certification (NY).

• Definitions are Tightening: The definition of "intentionally added PFAS" (RI) now includes degradation products. "Regulated PFAS" (NY) introduces a total organic fluorine threshold, significantly broadening the regulatory net.

• Supply Chain Liability is Clarified: New York's certificate of compliance system clearly delineates responsibilities between manufacturers and retailers.

• Long-Term Roadmap is Clear: Ohio's 2033 comprehensive ban deadline signals that PFAS phase-out is a long-term regulatory direction.

Manufacturers should check the product lists, reporting/registration obligations, exemption conditions, and effective dates for each state where their products are sold and take action in advance to establish corresponding product compliance verification and information disclosure processes.

Following a DEFRA policy announcement on 24 February 2026, the UK has retired its post-Brexit "Interim Principles" for identifying SVHCs and moved towards closer alignment with the EU REACH Candidate List. As a result, 26 substances have been added to the UK Registry of Intentions for SVHCs. A public consultation for the first 15 substances opened on 9 March 2026, with a deadline of 20 April 2026. The remaining 11 substances are planned for a second consultation batch in June 2026.

The Department for Environment, Food and Rural Affairs (DEFRA) policy announcement on 24 February 2026 marks a strategic shift in the United Kingdom’s (UK's) approach to Substances of Very High Concern (SVHCs) under the UK registration, evaluation, authorization and restriction of chemicals regulation (UK REACH). The "Interim Principles" established after the UK's exit from the European Union (EU) in 2021 have been officially retired. The UK is now pursuing systematic alignment with the EU REACH Candidate List, reviewing substances added to the EU list since 2021. The UK Registry of Intentions (ROI) is the UK's early warning mechanism, allowing industry to comment on proposed SVHCs and begin substitution planning before formal Candidate List inclusion. Up until now, 26 entries have been added to the UK ROI-SVHC list. These represent the UK's systematic review of substances added to the EU Candidate List since 2021.

On 11 March 2026, the UK Health and Safety Executive (HSE) launched its first formal public consultation to add 15 substances to the UK REACH Candidate List. The public consultation will be closed on 20 April 2026. The remaining 11 entries on the UK Registry of Intentions are to be included in the second batch for consultation in June 2026.

The initial public consultation of 15 substances includes the following:

Because these are already EU REACH SVHC, global supply chains should ideally already be tracking them. The primary change is the legal notification requirement specifically within the UK (Great Britain) market.

The European Commission published the Safety Gate 2025 Annual Report, detailing the performance of the Safety Gate Rapid Alert System for dangerous non-food products under the General Product Safety Regulation (GPSR – Regulation (EU) 2023/988), applicable since 13 December 2024. In 2025, a total of 4,671 alerts and 5,794 follow-up actions were validated. The report identifies cosmetics, toys, and electrical appliances as the top notified product categories, with chemical risk as the predominant type of risk. It also highlights key regulatory and enforcement developments, including AI-powered market surveillance tools, the Consumer Safety Gateway, and the adoption of the Principles for Consumer Product Safety of the United Nations.

The European Commission published the Safety Gate 2025 Annual Report, providing a comprehensive overview of product safety alerts circulated among European Union (EU) and European Economic Area (EEA) Member States. The Safety Gate Rapid Alert System is governed by the General Product Safety Regulation (GPSR – Regulation (EU) 2023/988), applicable since 13 December 2024, which requires all products placed on the European market to be safe.

In 2025, 4,671 alerts were notified in the Safety Gate system, the highest recorded number since the system was launched in 2003. This is a 13% increase compared to 2024, and more than double the number of alerts reported in 2022. National authorities also issued a record number of follow-up actions, with 5,794 follow-up actions notified, which is a 35% increase compared to the previous year. This reflects the growing effectiveness of the system, reinforced under the General Product Safety Regulation; it allows for an increasingly systematic sharing of information between market surveillance authorities across the EU and EEA.

Major Findings

1. Top three most notified product categories

• Cosmetics - 36%

• Toys - 16%

• Electrical Appliances and equipment - 11%

'Cosmetics' is the most frequently notified product category on Safety Gate for the third year, representing each year around a third of the alerts validated. Specific to the alerts concerning cosmetics, 77% were related to the presence of 2-(4-tert-butylbenzyl) propionaldehyde (BMHCA, also known as 'Lilial'), a banned synthetic fragrance which can have harmful effects on the reproductive system and cause skin irritation.

2. Top three most notified types of risk

• Chemical - 53%

• Injury 14%

• Choking 9%

Chemical

• BMHCA in cosmetics , which has been prohibited since March 2022, accounted for a large share of the alerts signaling a chemical risk reported

• Diphenyl(2,4,6-trimethylbenzoyl) phosphine oxide (TPO) which was banned in cosmetic products in September 2025 and is found in nail polish. This demonstrates the authorities’ close monitoring of newly adopted chemical restrictions and their swift enforcement actions to remove non‑compliant products from the market and reduce risks to consumers.

• Phthalates which are still very often detected in plastic toys and other products for children.

• Lead which is very often found in solders.

• Short-chain chlorinated paraffins (SCCPs) which are found in cables.

Injury

General injury risks were also very commonly identified among the alerts validated in 2025. These included incidents ranging from motor vehicle accidents to childcare products or toys that fail to adequately protect children from falls or other injuries.

Choking

This risk primarily affects young children and is often linked to small components in toys or clothing, such as buttons or decorative elements. As young children frequently place objects in their mouths, these small parts may be swallowed, leading to choking. In particular, the ingestion of small or button batteries can be fatal due to the chemical reactions they trigger within the digestive tract.

3. Highlighted initiatives regarding EU product safety policy

The Commission supports market surveillance authorities with AI‑enabled web‑crawling tools to strengthen online product safety enforcement. These tools detect dangerous, unsafe, or non‑compliant products on online marketplaces and facilitate rapid action. 20,800+ dangerous product URLs were identified by AI crawlers in 2025. Online marketplaces operating in the EU are required under the General Product Safety Regulation to register in the Safety Gate Portal and provide a single point of contact. Several providers have voluntarily committed, through the Product Safety Pledge+, to proactively monitor Safety Gate and remove dangerous products from their platforms.

Next steps

The Commission, in cooperation with national market surveillance authorities, is preparing the 2026 product safety sweep to verify compliance with the General Product Safety Regulation. A “sweep” consists of coordinated online checks conducted simultaneously to identify infringements of EU product safety requirements in a specific sector.

In parallel, the Commission is organizing Coordinated Actions for Product Safety, under which national authorities jointly test selected products and exchange best practices to strengthen market surveillance.

The updated Saudi Technical Regulation for Textile Products establishes strengthened safety, chemical, labeling and conformity assessment requirements for textile products sold in the Kingdom. It expands obligations for economic operators, enhances chemical restrictions, clarifies fiber‑labeling rules, and aligns conformity modules with national product safety regulations.

It enters into force within 180 days from publication in the Official Gazette, with an additional correction period of up to 365 days for economic operators to regularise their status. Previously issued regulations in the same field are repealed upon entry into force.

On 02 Mar 2026 , the Kingdom of Saudi Arabia updated the Technical Regulation for Textile Products (TR No. A.M 164-18-05-02) to enhance the safety, chemical, labeling and conformity assessment requirements for textile products sold within the Kingdom. Additional details are outlined below:

1. Scope

• Applies to textile products containing ≥80% textile fibers, including garments, fabrics, home textiles and composite products.

• Exemptions include medical products and regulated footwear.

2. Strengthened Obligations for Economic Operators

• Manufacturers must ensure pre‑market compliance, issue a Declaration of Conformity (DoC), maintain 10‑year documentation, conduct risk assessments, ensure Arabic labeling, and manage recalls and consumer complaints.

• Importers must verify conformity before importation, add importer information, maintain local DoC + technical file for 10 years.

• Distributors must verify compliance before sale, ensure storage safety, and support market surveillance.

3. Enhanced Technical Requirements

• Chemical Restrictions: bans/limits heavy metals, formaldehyde, organotin compounds, phthalates, pesticides, chlorinated organics, azo dyes, carcinogenic amines, allergenic dyes, perfluorooctane sulfonate (PFOS)/perfluorooctanoic acid (PFOA), carcinogenic, mutagenic, or toxic for reproduction (CMR) substances, Persistent, Bio-accumulative and Toxic (PBT)/very Persistent and very Bioaccumulative (vPvB) chemicals.

• Skin Safety: pH must be within safe range, colorfastness tests for wash, sweat, saliva (children) must meet limits.

• Children's Safety (<36 months): strict rules on small parts, cords, accessories, and mandatory Type 3 conformity.

4. Labeling Requirements

• Mandatory Arabic labels with allowed bilingual versions.

• Must include fiber composition (accuracy ±5%), care instructions, origin, supplier name/Commercial Registration (CR) number, and chemical treatment disclosures.

• Fiber names must match the Annex 3 list; multi‑layer products require component‑specific declarations.

5. Conformity Assessment

• Type 1a for most textile products: design‑based conformity with approved body testing.

• Type 3 for children’s textiles <36 months and underwear: factory assessment, sampling, ongoing surveillance.

6. Enforcement

• Authorities may conduct random inspections, order recalls, impose penalties, and revoke certificates.

7. Summary Comparison: Updated Version vs Previous Version

• Expanded scope and precise ≥80% fiber rule.

• Added new high‑risk category for children’s products and stricter small‑parts requirements.

• Expanded major chemical safety initiatives including PFOS/PFOA and substances classified as carcinogenic, mutagenic, or toxic for reproduction (CMR) categories.

• Included full alignment with General Conformity Assessment Models (Type 1a / Type 3).

• Strengthened labeling with detailed component‑level rules.

• Increased documentation retention to 10 years.

• Outlined clearer enforcement authority and penalties.

Effective date of the Updated Technical Regulation for Textile Products (TR No. A.M 164-18-05-02: It shall take effect within 180 days from the date of publication of the official gazette.