What’s Trending in Compliance? February 2026
This blog was originally posted on 23rd February, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.
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Below we break down some of the top compliance trends in February 2026 that are generating the most interest globally this month.
1. EU: Details and Format for the Disclosure of Information on Discarded Unsold Consumer Products Under Regulation (EU) 2024/1781, Regulation (EU) 2026/2
On 9 February 2026, the European Commission approved Regulation (EU) 2026/2 laying down rules for the application of the EU ESPR (Regulation 2024/1781), specifically concerning the details and format for disclosing information on discarded unsold consumer products. It also covers the verification of this information.
The new rules for disclosing information on unsold consumer products will apply to products discarded starting from the first full financial year after the date of application of this regulation (2 March 2027). Economic operators shall disclose that information within 12 months after the end of that financial year.
The disclosed information on discarded unsold consumer products must follow the specific visual presentation and content format detailed in Annex I. If a business already publishes sustainability reports (either voluntarily or as required by Directive 2013/34/EU) and includes the necessary information in the specified format, they can simply provide a link on their website to that report, clearly stating that it contains the information on discarded unsold consumer products.
Information on discarded unsold consumer products should be categorized using the first two digits of the Combined Nomenclature (CN) codes. However, for products specifically listed in Annex II, the first four-digit CN codes must be used for more detailed differentiation.
Annex III sets out the procedure to be used by competent authorities to verify the disclosure.
2. UK: PFAS Plan: Building a Safer Future Together, Policy Paper, February 2026
On 3 February 2026, the UK Department for Environment, Food & Rural Affairs (Defra) published PFAS Plan: Building a Safer Future Together, which sets out the UK government’s framework for managing risks associated with per- and polyfluoroalkyl substances (PFAS).
The main body of the plan is organized into three sections:
- Section 1 (Understanding PFAS sources) describes the current evidence on PFAS uses, their prevalence in the environment, and routes of human and environmental exposure. It also covers monitoring programmes and research activities intended to strengthen the evidence base.
- Section 2 (Tackling PFAS pathways) sets out regulatory controls applicable to PFAS across their lifecycle, including restrictions under international conventions and UK REACH, controls under environmental permitting and waste regimes, and measures addressing PFAS in products, emissions, and disposal.
- Section 3 (Reducing ongoing exposure) focuses on the management of existing PFAS exposure through controls and monitoring relating to drinking water, food and food contact materials, consumer products, contaminated land, and environmental waters.
In the Next Steps section, the plan explains how delivery of the framework will be taken forward and tracked. It provides a consolidated list of indicative actions drawn from all three sections, setting out for each action the territorial scope, responsible authority, and delivery outlook. The implementation of the plan will be reviewed and reported through the statutory reporting cycle under the Environment Improvement Plan.
In addition, it notes that future work under the plan will include consideration of further UK REACH restrictions on PFAS, including consideration of consumer articles and specific product groups, and continued implementation of prohibitions under the Stockholm Convention on Persistent Organic Pollutants on PFAS substances placed on the market.
3. Maine (USA): Implementation of Maine Law Regulating Products Containing Perfluoroalkyl and Polyfluoroalkyl Substances, Report, January 2026
On 21 January 2026, the Maine Department of Environmental Protection (DEP) published its Report on the Implementation of Maine Law Regulating Products Containing Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS).
Maine law establishes product-specific prohibitions on the sale of products containing intentionally added PFAS, culminating in a broad ban on the sale of such products in Maine, subject to limited exemptions. Products may continue to be sold only if the DEP determines through rulemaking that the PFAS use qualifies as a Currently Unavoidable Use (CUU).
The PFAS in Products Program was created by Public Law 2021, chapter 477 (LD 1503). It was substantially amended by Public Law 2023, chapter 630 (LD 1537), which took effect on August 9, 2024. These amendments eliminated the general PFAS notification requirement that was scheduled to begin January 1, 2025, and instead established new, staggered sales prohibitions for products with intentionally added PFAS. The amendments also created specific exemptions and introduced a new reporting requirement for product categories granted a CUU determination.
The DEP’s amended Chapter 90 rule, which includes CUU determinations, became effective on October 7, 2025. Manufacturers whose products are covered by an approved CUU must submit a PFAS Notification Form and pay the required fee to continue selling, offering for sale, or distributing affected products in Maine once the applicable sales prohibitions take effect on January 1, 2026.
The report outlines the DEP’s implementation efforts, summarizes a comparable federal program, compares Maine’s approach with other states that regulate PFAS in products, and identifies key implementation challenges.
In its conclusions, the DEP does not recommend legislative changes to 38 M.R.S. § 1614 in 2026. The statute has been amended twice since its enactment in 2021, and the implementing rule was finalized in 2025. However, the DEP identified opportunities to clarify statutory prohibitions, exemptions, and the CUU evaluation process through rulemaking. In 2026, the Department plans to revise Chapter 90 and update guidance materials to support manufacturer compliance.
The DEP anticipates that some manufacturers may be subject to the January 1, 2026 sales prohibition without realizing their products are affected. Determining applicability may require careful analysis of statutory language, legislative history, and comparable state programs. The Department will rely on its existing compliance and enforcement authorities and will consider feedback from the Legislature’s Environment and Natural Resources Committee as it develops future rule revisions, guidance, and applicability determinations.
4. EU: Questions and Answers on New Article 27A of CBAM, Q&A Document, January 2026
In January 2026, the EU Commission issued a Q&A document offering clarification on the operationalization of the newly proposed Article 27A under Regulation (EU) 2023/956 establishing the Carbon Border Adjustment Mechanism (CBAM).
Article 27A was introduced as part of the proposal issued on 17 December 2025 concerning the inclusion of additional downstream products in the scope of CBAM. This new article allows the EU Commission to temporarily remove specific CBAM goods from the scope of the Regulation if their inclusion causes severe harm to the EU internal market due to serious and unforeseen impact on the price of these goods.
In this Q&A document, the Commission clarifies when and how the Commission is empowered to remove a CBAM good from Annex I in the event of unforeseen impacts on the internal market. The European Commission would first be required to assess relevant evidence demonstrating that the impact of the CBAM on the price of certain goods causes significant harm to the Union’s internal market. If the Commission concludes that a particular CBAM good should no longer be covered, it would be empowered to issue a delegated act to remove the affected good from Annex I of the CBAM Regulation.
The document also confirms that the removal of affected goods may have retroactive effect. In such cases, authorized declarants who purchased CBAM certificates for imports of the affected goods (imported in 2026 or thereafter) may be reimbursed for the price paid for those certificates.
5. Singapore: Extending Minimum Energy Performance Standards (MEE) and Mandatory Energy Labelling Scheme (MELS) to All Regulated Goods Imported by End-Users for Their Own Use, Consultation Paper, January 2026
In January 2026, the Singapore National Environment Agency (NEA) published a consultation paper seeking public feedback on extending Minimum Energy Performance Standards (MEPS) and Mandatory Energy Labelling Scheme (MELS) requirements to all Regulated Goods imported by end-users for their own use.
Currently, Regulated Goods imported directly by end-users, that is, not through local suppliers or dealers, for their own use are not subject to MEPS and MELS requirements as mandated by the Energy Conservation Act. This proposal seeks to ensure that such products, including those procured by users through online platforms not based in Singapore, also meet the high energy standards that locally supplied products do. Regulated Goods imported for own use are proposed to be subject to the following requirements:
- Registration with the NEA where applicable fees shall apply;
- Satisfaction with MEPS test requirements; and
- Compliance with labelling requirements under MELS.
The list of Regulated Goods includes certain types of air-conditioners, refrigerators, televisions, water heaters, etc.
The proposed changes to the Energy Conservation Act are aimed to enter into force for all imported Regulated Goods starting from 1 July 2026.
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The top compliance trends in February 2026 is based on the most viewed regulations on C2P this month. If you would like to see C2P in action, book time with our team to witness the true power behind C2P.
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