How to Get Ahead in Q3: Your Product Material Compliance Priorities

Regulators aren’t slowing down, and 2026 is on pace to be the busiest year yet for new technical trade barriers globally. Customer requests for compliance data are climbing just as fast (sometimes even tripling year over year), and most compliance teams simply aren’t scaling at the same rate. 

We call this the risk exposure gap: the growing distance between what regulators and customers demand vs. what you have the bandwidth to deliver. To really close the risk exposure gap, you need regulatory expertise to know where to focus your attention each quarter.

Assent’s experts track regulatory trends, changes, and deadlines so you don’t have to. Here’s what’s changing, what’s still genuinely unresolved, and what we think manufacturers should prioritize between now and the end of the year.

PFAS Risk Management Is No Longer a Single-Jurisdiction Problem

PFAS regulations at the state, federal, and global levels are beyond the point where you can treat them as a single “PFAS checkbox” in your supply chain program. The EU and the U.S. are taking separate but similar approaches to governing PFAS, and both are accelerating.

In the EU, the REACH Annex XVII universal PFAS restriction has moved through its second phase. The Risk Assessment Committee (RAC) has confirmed that an EU-wide restriction is warranted on human health and environmental grounds. 

Three scenarios keep coming up in the EU PFAS discussion:

• If no viable alternative exists (fluoropolymers are the standing example)
• When the application involves extreme performance conditions (seals, gaskets, and membranes that must survive severe chemical, thermal, or pressure environments)
• If the product has a long service life — think fifteen to thirty years — where an eighteen-month transition window isn’t enough time to qualify a replacement material.

If any of these apply to your product, you have a rough map of where you’re likely to get breathing room and where you won’t. Waiting for the European Commission’s final rule to start your PFAS assessment is the wrong way to approach this. The derogation logic is visible now, and the qualification cycles for alternative materials are long enough that you need to start immediately.

The U.S. PFAS compliance picture is just as active, but more fragmented:

• The start date for federal reporting under TSCA Section 8(a)(7) has shifted and is expected to be finalized by year-end. 
• Minnesota’s product reporting obligation takes effect September 15, with a possible extension to December. 
• Connecticut’s reporting and labeling requirement for intentionally added PFAS landed July 1 — effectively immediately — with sales restrictions to follow in 2028. 
• New Mexico’s labeling rule, finalized for products manufactured on or after January 1, 2027, is notable for being arguably the strictest labeling approach in the U.S. right now.

To further complicate things, there’s a supply chain visibility problem sitting underneath all this that doesn’t get enough attention: PFAS in plating, coatings, and finishing processes often don’t show up on a safety data sheet (SDS). Polymers aren’t registered under EU rules, and non-hazardous materials generally aren’t listed on SDSs even when they contain PFAS. That means the document most compliance teams instinctively reach for is often the wrong tool for this specific situation. 

Supplier surveys that specifically ask about intentionally added PFAS are doing work the SDS was never designed to do. If your PFAS program still routes primarily through SDS collection, you have serious compliance risks hidden just outside your line of sight. 

You need a PFAS plan. Assent has you covered. Download the PFAS Handbook now.

PPWR: Still Being Defined, but Don’t Delay

The Packaging and Packaging Waste Regulation (PPWR) is a good example of why manufacturers shouldn’t wait for absolute regulatory certainty before they act. Some requirements are still waiting to be clarified, but compliance means getting ahead of your packaging data now. 

Two obligations take effect in August 2026: 

• A 100 mg/kg limit on heavy metals (lead, cadmium, mercury, hexavalent chromium) in packaging
• A food-contact material PFAS restriction 

Neither is new in concept. The heavy metals limit existed under the prior packaging directive, but the regulation mandates uniform enforcement across every EU member state.

The more consequential shift is the concept of “substances of concern” (SOC), which now pulls in the existing REACH SVHC list (253 entries), the EU’s persistent organic pollutants list (34 entries), and roughly 3,000+ entries from Annex VI of the Classification, Labelling, and Packaging (CLP) Regulation covering harmonized hazard classifications. Minimization obligations for these substances also start in August 2026, with labeling requirements following in August 2028.

There’s a fourth category within SOC that would include substances that negatively affect reuse and recycling. However, it is still largely undefined and won’t be clarified until a delegated act arrives in the coming months. 

Some compliance teams are treating this as “not yet in scope” and deferring it. We’d argue that’s backwards. The categories that are already defined at least give you a target to minimize against. The undefined category is the one that should worry you most, because you can’t yet build a compliance program against a moving target. That means the only defensible position right now is broad substance visibility across your full packaging bill of materials, not narrow tracking against today’s known lists.

There’s also a legal-manufacturer trap to be aware of: If your name or trademark appears on packaging, you are the legal manufacturer under PPWR, even if a third party physically produced it. The obligation doesn’t transfer just because you outsourced production. 

The Packaging and Packaging Waste Regulation got you confused? Read Assent’s PPWR Scoping Guide for clarity on who and what is covered by PPWR requirements.

CBAM Reporting Is Becoming a Competitive Issue, Not Just a Compliance One

CBAM often gets filed under “not my problem” by manufacturers who don’t import directly into the EU. That’s a mistake.

The EU is now in its permanent CBAM phase, with the first annual declaration and certificate surrender due September 2026 against imports made this year. The UK’s parallel CBAM starts January 1, 2027, with no transitional phase. A proposal to expand EU CBAM’s scope to roughly 180 downstream products (household goods like dishwashers, and essentially anything with meaningful embedded steel, iron, or aluminum) is also in play for January 2028, and it’s worth tracking even if it feels early.

We’re keeping track of the current CBAM timeline here. Check out how much (or how little) time you have left to collect supply network data to report correctly. 

Here’s the part that matters even if you’re several tiers removed from being a CBAM declarant yourself: Your customers who are declarants are increasingly asking their suppliers for installation-level emissions data. The reason is straightforward economics. CBAM declarants choose between actual emissions values from their supply chain or default values published by the European Commission, and the default values are deliberately punitive, carrying a built-in markup specifically to encourage the use of real data. 

A supplier that can provide actual emissions data hands their customer a potentially lower carbon tax. Goods without emissions transparency are becoming structurally more expensive to move through CBAM-regulated trade, and that cost difference is visible to procurement teams making sourcing decisions. In a durable goods sector where steel, aluminum, and other CBAM-covered inputs are common, the ability to give a customer real emissions data instead of a punitive default is a real competitive advantage. 

In scope of CBAM or have customers who are? Assent’s CBAM solution was built for you. Take an interactive tour of it here.

Product Intelligence Is the Differentiator

The dates on your regulatory calendar are more or less set, but your competitive position isn’t, especially when there’s always a new requirement on the horizon. 

By the time a rule is final, every compliance team in your sector has read the same summary you have. What will put you ahead of competitors is access to product intelligence from your supply chain that lets you be the first one ready to generate compliance declarations or source materials for product redesigns. 

That’s the work worth prioritizing over the next few months, and it’s exactly where Assent’s network and regulatory expertise are built to help: centralizing supply chain data, closing visibility gaps, and giving your team the bandwidth to focus on strategy instead of chasing suppliers for surveys.

Don’t go it alone. The Assent Network connects you to product intelligence data and regulatory expertise that makes regulatory compliance simpler. Book a demo to speak with an expert.