As manufacturers and distributors prepare for 2026, proactive data collection and designing for compliance at the part level will be critical for risk reduction. Regulatory momentum in 2025 set new expectations across chemical safety, sustainability, and due diligence, and in 2026, you will see these expectations evolve into more complex regulatory obligations.
Hear from our experts below about the regulatory forces shaping your product compliance requirements and how you can set your company up for success in 2026 and beyond.
How 2025 Set Due Diligence Requirements in Motion
Chemical Regulations: Hazard-Centric Policy Takes Hold
Global regulators continue to move toward hazard-based chemical controls. This means entire classes of chemicals are facing bans, and long-standing legal exemptions are changing. For instance, market pressure accelerated per- and polyfluoroalkyl substances (PFAS) phase-outs, as did regulatory bans under U.S. state legislation and Europe’s REACH Annex XVII proposal.
Extended Producer Responsibility (EPR)
EPR requirements rose in prominence as more jurisdictions placed end-of-life financial responsibility on manufacturers. Alongside these financial obligations, manufacturers now face strict data gathering requirements, necessitating granular tracking of material specifications and volumes. These policies are reshaping how companies design products and packaging to ensure cost-effective disposal management.
Supply Chain Due Diligence
Companies that cannot demonstrate supply chain traceability face a greater risk of fines, trade disruptions, and revenue losses. If you can’t track county of origin in your value chain, you can’t protect yourself from unexpected tariffs, sanctions, or border detentions that freeze your inventory overnight.
2026: A Year for Proactive Compliance & Strategic Alignment
Going into 2026, businesses should view the coming year not as a continuation of burdens, but as an opportunity to cement their leadership in sustainability-focused operations.
Chemical Regulations: PFAS, California Proposition 65 & Beyond
PFAS requirements will continue to expand in 2026, with global markets taking a stronger stance. In Europe, the final public consultation process for REACH Annex XVII’s PFAS ban will leave companies with a narrow window to submit technical justifications for needed derogations. Ahead of the final consultation period in 2026, manufacturers must assess the proposed derogations to ensure they fully encompass their specific applications of PFAS. At the same time, industry stakeholders must urgently secure continued access to essential PFAS materials, as major chemical producers are exiting the PFAS business.
The regulatory adjustments don’t stop in the EU. In the U.S., state-specific PFAS legislation will fill perceived gaps created by proposed amendments to federal TSCA Section 8(a)(7) reporting requirements. This includes Minnesota’s PFAS Reporting Information System for Manufacturers (PRISM), where annual reporting will begin by July 1, 2026.
In 2026, manufacturers will also need to prepare for California’s stricter short-form warnings under Proposition 65, which requires that specific chemicals be named on labels after January 2028.
In addition, the EU Persistent Organic Pollutants (POPs) Regulation is expected to expand following recent additions to the Stockholm Convention. Companies must address these requirements while managing the routine inclusion of new substances of very high concern (SVHCs) to the EU REACH Candidate List two to three times per year.
Digital Product Passport & Circular Economy Mandates
The European Union will likely be moving forward with the Digital Product Passport (DPP), a cornerstone of the Ecodesign for Sustainable Products Regulation (ESPR). Manufacturers of in-scope products, starting with iron and steel in 2026, will need to provide granular material-level insights into their products. This initiative will make sustainability obligations mandatory. Manufacturers must begin applying circular design principles and verifying product composition against evolving sustainability standards. Compliance starts at the material level, with due diligence serving as the foundation for both regulatory obligations and differentiation in customer markets.
Carbon Border Adjustment Mechanism (CBAM) Enters Permanent Application
In 2026, the EU’s Carbon Border Adjustment Mechanism (CBAM) will transition into permanent operation. The de minimis thresholds have been raised for reporting exclusions, and this will reduce the burden for approximately 90% of companies that were in scope of initial CBAM obligations. However, scrutiny of emissions will continue, and regulators will demand robust data from importers to calculate embedded carbon.
Extended Producer Responsibility Expands Across Borders
Building on the foundation laid in 2025, U.S. packaging EPR reporting will expand to seven states in 2026 as Maine, Maryland, and Washington activate their requirements. This will create an intensified data burden that extends deep into the supply chain. Manufacturers and their suppliers must now manage increasingly complex reporting obligations alongside financial duties, while legislative proposals in other states continue to ramp up the pressure for circular packaging solutions.
EU Regulatory Developments: EU Batteries Regulation, Deforestation Regulation & REACH 2.0
Batteries & Deforestation Regulations
The EU experienced delays for a number of supply chain sustainability regulations, including the EU Batteries Regulation (EUBR) and the EU Deforestation Regulation (EUDR).
- The EUBR due diligence reporting deadline has been extended to August 18, 2027
- The EUDR deadline is delayed to December 30, 2026
While these delays offer additional preparation time, they underscore the need for deeper supply chain data. The information that underpins compliance will come directly from your supply chain, so it’s vital to use this time to engage suppliers for the necessary declarations.
REACH 2.0
Looking ahead, the long-anticipated REACH 2.0 framework is expected to surface in 2026, bringing fundamental revisions to Europe’s chemical safety regulations.
Action Plan for 2026: Your Next Steps
- Strengthen Supply Chain Data Management
Companies will need greater visibility into upstream and downstream partners to comply with PFAS restrictions, CBAM reporting, and circular economy mandates. Be sure to maintain a database of accurate trade data, including HS codes, certificates of origin, and emissions information. Use third-party partnerships to close data gaps.
- Prepare for Circular Economy Compliance
Begin adopting circular design methodologies, with emphasis on material composition, recycled content, recyclability, and end-of-life outcomes. Upcoming ESPR and DPP requirements will demand this level of detail.
- Engage Early on Chemical & Market-Shaping Regulations
Industries affected by PFAS restrictions or REACH 2.0 should engage in regulatory consultations and ensure technical documentation is prepared early. Align product strategies with regional nuances to avoid costly redesign cycles.
- Track State-Specific EPR Requirements in the United States
Companies operating across multiple states need tailored strategies for each jurisdiction’s EPR rules. Monitor scope requirements, packaging obligations, and reporting expectations. Seek guidance from expert organizations to operationalize compliance efficiently.
2026 Will Reward the Proactive
Regulatory expectations in 2026 will require precision, credible data, and the ability to adapt quickly as rules evolve. Compliance teams cannot meet these requirements with static spreadsheets or fragmented supplier outreach. They need a systematic approach that delivers reliable visibility into materials, processes, and supplier performance.
Assent’s AI-native supply chain sustainability software centralizes product and supply chain data, connects directly with suppliers to improve response rates, and automates the collection of information required for PFAS reporting, CBAM submissions, DPP readiness, and emerging EPR mandates.
The organizations that lead in 2026 will be those that invest now in the infrastructure to manage regulatory complexity at scale. Assent helps you get there with speed and confidence. Speak with one of our experts to kickstart your 2026 program planning.
Disclaimer
This article is provided for informational purposes only and does not constitute legal or regulatory advice. The information is current as of the date of publication and may become outdated as regulations evolve. Assent makes no representation that the content will remain accurate after this date. No client relationship is created.
