The Biweekly Pulse: 1st – 12th December – PFAS, UK Product Regulation and Metrology Act, and EU RoHS Updates
The Pulse was originally posted on 17th December, 2025. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.
Check out the latest 2025 Regulatory Compliance Updates with The Pulse, your biweekly source for global regulatory insights!
This Week’s Trending Sources in C2P
- PFAS – United States Key Regulatory Developments, Whitepaper, December 2025
- Packaging in Canada: A 2025 Roundup and Looking Ahead to 2026, December 2025
- Regulatory Developments in Consumer Electronics – December 2025, Blog, December 2025
What is Our Content Team Talking About?
RoHS: EU Updates Exemption Validity and Rolling Plan
by Joyce Costello, Senior Regulatory Compliance Specialist
The EU Commission has updated its RoHS exemption validity and rolling plan providing an overview of Annex III and IV exemptions including their validity status and submitted exemption requests, replacing the previous plan dated September 2025.
The modified plan, published on 8 December 2025, is current to 8 October 2025, and reflects the continued validity of the following exemption, given that a request for its renewal was submitted in due time:
Annex III 1(f) – I Mercury in lamps designed to emit mainly light in the ultraviolet spectrum: 5 mg (renewal requested on 22 August 2025).
The following exemption is now earmarked as no longer renewable, as no renewal application was received by the Commission by the submission deadline of 30 September 2025:
Annex IV 44 Cadmium in radiation tolerant video camera tubes designed for cameras with a centre resolution greater than 450 TV lines which are used in environments with ionizing radiation exposure exceeding 100 Gy/hour and a total dose in excess of 100kGy (Applies to category 9 – Expires on 31 March 2027).
Exemptions are listed numerically, with the formulation, scope and applicability shown in the cell’s comment. Both exemption start and end dates are shown, along with the date of the first renewal request submitted in due time (at least 18 months before the end date).
Note that this document has no legal effect and is published by the EU Commission for reference purposes only.
What Are Our Knowledge Partners Talking About?
Product Regulation and Metrology Act: What a New Legal Landscape for UK Product Safety Means for Businesses?
by RINA
Context
On 21 July 2025, the Product Regulation and Metrology Act 2025 (PRAM Act) received Royal Assent, giving the UK government broad powers in a new UK law that sets out a framework for product safety and metrology (the science of measurement).
Before the PRAM 2025, the UK GPSR 2005 (General Product Safety Regulations) was one of the UK’s product safety laws. Following Brexit, the UK retained the UK GPSR 2005, as part of its retained EU law. The retained EU law made it harder to respond swiftly to emerging risks due to the complexity of legislative processes in the UK. Effectively, the UK needed to pass this act to retain the EU law. The new Act provides a flexible structure for the UK government to update product safety laws through secondary legislation without needing fresh primary legislation.
Overview
The new Act introduces a broader scope, broadly defined as tangible goods, including consumer goods and toys. While still focused on tangible goods, the Act acknowledges that software can be an integral component of product safety. Categories like food, medicines, medical devices, military equipment, and aircrafts are excluded under Schedule 1 of the Act. The new scoping allows the regulation of manufacturers, importers, distributors, installers, and online marketplaces, in an effort to make the supply chain more accountable. This move makes room for future rules to be tailored at the product risk level, rather than rigid categories like “toys” or “electronics”.
The PRAM opens the door for the UK to align with EU product standards if it’s beneficial but doesn’t commit to doing so. UK authorities can in effect mirror or diverge from relevant EU product and environmental standards, like GSPR or Ecodesign requirements, if that supports UK interests.
The PRAM doesn’t make major changes immediately, but it gives the government broad powers to update product safety rules through future regulations. Developments can be seen as the government sets to introduce secondary legislation to detail specific rules, especially for online marketplaces and high-risk products like e-bikes and e-scooters with lithium-ion batteries.
Next Steps
Businesses must review products that aren’t currently covered by sector specific law as these may get caught out under the new scoping of tangible products. If businesses sell products across UK platforms, they should prepare to verify seller compliance, share product data, and manage digital safety claims. More robust record keeping practices will be important, like tracking complaints, documenting test results and maintaining traceability for authorities.
What Are Our Clients Asking About?
What are the Reporting Obligations on PFAS Presence as Recently Announced by the Australian Industrial Chemicals Introduction Scheme (AICIS)?
Answered by, Valentina Marchetti, Senior Regulatory Compliance Specialist & Team Lead
On 13 October 2025, the AICIS Executive Director initiated an evaluation under section 74 of the Industrial Chemicals Act 2019, focusing on 522 PFAS listed on the Australian Inventory of Industrial Chemicals (AIIC).
Section 74 empowers the Executive Director to undertake evaluations of industrial chemicals or classes of chemicals to better understand their hazards, exposures, uses, and introduction circumstances. In this case, the objective is to determine whether these PFAS have been introduced in Australia, the volumes involved, and the purposes for which they were introduced.
AICIS has issued formal notices to registered introducers (those registered between 1 September 2023 and 31 August 2025) requiring them to report:
- Whether they introduced any of the listed PFAS;
- The chemical name and CAS number, mode of introduction (import/manufacture), total volume, and end use;
- Reasons if any information cannot be provided.
This obligation applies to introductions of PFAS as industrial chemicals, that is, PFAS imported or manufactured as substances or in mixtures. The evaluation, as framed under section 74, is focused on the introduction and use of industrial chemicals and the potential associated exposures. It does not extend to PFAS contained solely within finished articles.
The official notice is available here.
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