Q4 2025 Global Chemical Regulatory Update by Substance: PFAS, Mercury, POPs and More
This blog was originally posted on 18th 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.
BASED ON THE WEBINAR CHEMICALS QUARTERLY – Q4 2025 REGULATORY UPDATE, BY KIM PLASSCHE, SENIOR REGULATORY CONTENT SPECIALIST, AND CASSIE PERSHYN, SENIOR REGULATORY CONSULTANT, COMPLIANCE & RISKS.
The Q4 2025 brought several new measures in global governance. Several countries enhanced risk assessments, increased the number of chemicals covered, and improved exposure limits, in addition to strengthening reporting obligations. All of these actions are influencing compliance planning for 2026.
These are not isolated regulatory actions, as such developments demonstrate broader structural changes. We have group-based regulation, risk assessment throughout the entire life cycle, shorter transition periods, and greater readiness for enforcement. Thus, manufacturers placing chemicals, mixtures, or articles on the market must anticipate regulatory guidelines, aligning their internal systems accordingly.This article is based on our webinar Chemicals Quarterly – Q4 2025 Regulatory Update, with subject matter experts Kim Plassche and Cassie Pershyn,. Through this text, we are going to examine the most significant Q4 2025 developments by substance and their operational implications for manufacturers entering 2026.
PFAS
Among the most popular elements of the Q4 2025 chemicals regulatory update is the continued expansion of PFAS (per- and polyfluoroalkyl substances) regulation.
With the AICIS Request for PFAS Presence, Australia initiated a formal evaluation of 522 PFAS listed on their Inventory of Industrial Chemicals to better understand their prevalence and use within the country. This aims to determine which of these “forever chemicals” are currently in the Australian market, the volumes being introduced, and their specific end-uses. The data collected will serve as a foundation for further regulatory evaluations and potential future restrictions.
Australia
AICIS (Australian Industrial Chemicals Introduction Scheme) issued formal notices to all businesses registered as chemical introducers. They are now legally required to disclose whether they have imported or manufactured any of the listed PFAS since 2023. Companies must provide specific details. This includes CAS (Chemical Abstracts Service) registry numbers, introduction modes, and total volumes. Failure to provide this information must be justified. There is also a voluntary request for data from earlier years to help build a comprehensive risk profile.
This move signals an intensifying regulatory focus on PFAS in Australia. This align with global trends to tighten oversight on chemicals known for environmental persistence and health risks. For companies operating in the region, it’s a mark of a critical phase of compliance and transparency regarding their chemical portfolios.
The proposed TSCA PFAS reporting requirements significantly narrow the reporting scope by 0.1% de minimis threshold and exempting imported articles. The pivot specifically addresses the administrative hurdle of retrospective data collection. This effectively shields over 127,000 small businesses from a massive compliance burden, while focusing on the most commercially significant chemical volumes.
United States: State-Level Convergence
While the scope is shrinking, the compliance window is tightening. The EPA (U.S. Environmental Protection Agency) proposes to halve the submission period from six months to just three. Furthermore, the timeline is no longer anchored to a fixed calendar date. Instead, the three-month window will be triggered 60 days after the final rule becomes effective. Despite these changes, the extensive lookback period reaching back to 2011 remains.
There is currently no official indication of when this proposal will be finalized. The ultimate decision hinges on the EPA’s review of public comments submitted by the December deadline. However, the agency’s continued push for a reporting window beginning in April 2026 suggests an internal goal to finalize the rule in early 2026.
Also, there were multiple advanced product-specific PFAS restrictions in 2025 for different U.S. states. Although with variations in scope and certain definitions, we have some constants in the categories of products affected, which include:
- Food contact materials
- Textiles and apparel
- Upholstered furniture
- Cosmetics and personal care products
- Juvenile products
In addition to the bans, the notification requirements demand that manufacturers disclose intentionally added PFAS. In some cases, they must provide concentration data. Our webinar highlighted that for many of the state-level prohibitions, exemptions are allowed for CUU (Currently Unavoidable Use) cases. Responsible parties should prepare any CUU justification documentation ahead of official implementation dates. Manufacturers must wait on official portals and forms to be available from state authorities.
Other Global Jurisdictions
The EU’s new Toy Regulation, (EU) 2025/2509, explicitly prohibits the intentional use of PFAS in toys, components of toys or micro-structurally distinct parts of toys. Beyond PFAS, the regulation tightens limits on several hazardous chemicals, including endocrine disruptors and other reprotoxic substances, extending protections beyond the older directive’s scope. Meanwhile, a Switzerland Amendment to their Chemical Ordinance adds restrictions on PFOA (perfluorooctanoic acid), PFOS (perfluorooctane sulfonate), and PFHxA (perfluorohexanoic acid) to the existing PFAS restrictions in certain articles made of textiles, leather, fur or skin, preparations such as waxes or cosmetic products, as well as food contact materials. India also proposed significant restrictions on PFAS and other chemical substances used in food contact materials.
Which are the compliance implications related to PFAS?
PFAS-related measures continue to create supply chain traceability challenges. Particularly in regulatory approaches that address PFAS as a group rather than as individual substances. Group-based frameworks and reporting mechanisms require companies to understand whether PFAS are present in products, components, or materials. This increases the need for accurate upstream data collection and internal substance tracking.
So, these developments suggest a compliance environment in which monitoring and disclosure obligations can precede or accompany restriction measures. Regulatory movement around PFAS continues to evolve. This reinforces the need for ongoing monitoring of reporting requirements and related regulatory actions.
Mercury
Mercury is part of broader global hazardous substance management efforts. The Q4 2025 global chemical regulatory update reflected continued alignment of national frameworks with international commitments addressing mercury use in products and industrial processes. Its controls are within the context of coordinated international action and corresponding domestic implementation measures.
Europe
A key development was EU Council Decision 2258, adopted on October 31st. It defines the European Union’s position for the sixth meeting of the Conference of the Parties to the Minamata Convention on mercury. The decision authorized EU support for proposed amendments to Annexes A and B of the Convention. These amendments target the reduction and eventual elimination of mercury use in various products and manufacturing processes.
Specifically, the EU position supports establishing new phase-out dates for certain mercury-added products listed in Annex A. This includes particular lamps and measuring instruments. It also supports further restrictions on industrial processes under Annex B that involve mercury or the substance compounds.
Amendments in the United Kingdom to its Control of Mercury regulations were published on December 2nd. They revise existing laws to further restrict mercury use in various products and applications. The proposal includes phased bans on the production, import, and export of specified mercury-added products and industrial uses.
By the end of 2025, smaller mercury-containing products were targeted. This is related to most button cell batteries with less than 2% mercury, cosmetics and soaps, and certain high-tech industrial switches. In addition, mercury use in polyurethane production processes and in larger assembled goods is being prohibited. Newly added products must comply with hazardous substance restrictions and labeling requirements by August 2027.
Asia
Both China and Taiwan also took significant steps to harmonize their national chemical regulations with the Minamata Convention. China proposed a comprehensive, phased ban on mercury-added products and industrial processes beginning at the end of 2025. This has a focus on button cell batteries, cosmetics, and specific industrial switches, before including a wide array of fluorescent lighting in 2026 and 2027. Beyond consumer goods, China is also prohibiting mercury in polyurethane production and larger assembled goods. Exemptions remain for scientific research and laboratory calibration.
Simultaneously, Taiwan proposed its own set of amendments to tighten controls on hazardous substances in accordance with global standards. This includes an update to its mercury rules.
Which are the compliance implications related to Mercury?
These regulatory developments affect product composition verification, particularly for mercury-added products subject to phase-out or restriction. The referenced measures also include controls impacting production, import, and export activities for specified mercury-containing goods.
In addition, labeling and documentation requirements were noted in connection with newly restricted products. Companies placing products on the market in affected jurisdictions must ensure alignment with updated hazardous substance restrictions and related compliance obligations as outlined in the measures discussed during Q4 2025.
POPs
The Q4 2025 global chemical regulatory update on POPs (Persistent Organic Pollutants) referenced actions tied to the Stockholm Convention and corresponding implementation measures within regional legislation. POPs continue to be addressed through formal listing processes under international agreements, with participating jurisdictions, specifically EU and Switzerland, incorporating those decisions into domestic regulatory frameworks.
Thus, restriction lists for POPs continue to expand as substances are added under the Stockholm Convention and subsequently integrated into national or regional laws. These updates were presented as part of routine alignment measures, ensuring that existing regulatory systems reflect newly adopted international decisions.
There were adjustments to concentration limits for certain listed POPs in articles and waste. These revisions align regulatory thresholds with established maximum concentration values and disposal requirements. In addition, updates affecting waste management reflect requirements tied to the handling and treatment of POPs-containing materials.
So, the Q4 2025 developments included newly listed substances, updated restriction parameters, and revisions connected to concentration values and waste provisions within the existing legislative framework.
Which are the compliance implications related to POPs?
According to our webinar, the governance and risk classification of the EU AI Act, AI compliance cannot be addressed in isolation. Companies facing greater difficulties with regulatiAs a consequence, these updates have implications for companies placing articles on the market that may contain listed POPs. Adjusted concentration limits may require verification of substance levels in products and materials to ensure compliance with updated thresholds.
Companies must pay attention to legacy inventory, particularly where substances newly listed under the Stockholm Convention become subject to restriction or waste-related provisions. Finally, because POPs measures are tied to international agreements and implemented regionally, market access considerations arise for companies operating across jurisdictions that adopt these updates within their domestic frameworks.
Other Notable Substance-Specific Updates
Although addition to PFAS, mercury, and POPs, we highlight broader substance-specific regulatory activity during Q4 2025 across multiple chemical categories. Flame retardants were referenced in connection with ongoing review and restriction efforts in Canada and Japan, including amendments and proposals affecting restricted substance lists and chemical management programs. Heavy metals were also identified as an active focus area in the new EU Toys Regulation, with updates involving adjustments to concentration limits and compliance obligations within certain product-specific frameworks.
There was additional regulatory movement through routine amendments, list updates, and revisions within established chemical control systems. These developments, spanning multiple jurisdictions and regulatory mechanisms such as substance inventories and restricted substance frameworks, reflected continued global legislative activity across the chemical compliance landscape.
Cross-Cutting Trends Identified in Q4 2025
The webinar presented trends that reflect structural patterns within existing chemical regulatory frameworks.
- Group-based regulation was referenced in connection with certain substance categories addressed as chemical families rather than individual substances.
- Lower thresholds were noted through adjustments to concentration limits within established legislation, particularly in relation to listed substances and waste provisions.
- Increased documentation demands were reflected in reporting requirements and formal legislative amendments tied to international alignment measures.
- Supply chain accountability appeared in updates affecting production, import, export, and market placement obligations.
Finally, convergence across jurisdictions was evident in the implementation of international convention decisions—such as those under the Minamata and Stockholm Conventions—into regional and national legislation discussed during the quarter.
Substance-Based Monitoring as a Compliance Strategy
The Q4 2025 global chemical regulatory update reflects continued regulatory activity across the globe in chemical families such as PFAS, mercury, and POPs. Because several measures involve group-based approaches and expanded listings, monitoring by chemical category supports clearer visibility into evolving obligations across jurisdictions.
Maintaining an up-to-date substance inventory helps organizations respond to newly listed substances, adjusted concentration limits, and reporting requirements referenced. Q4 2025 developments are a signal of some of the continued regulatory focus heading into 2026, reinforcing the need for ongoing, structured compliance monitoring.
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