The Biweekly Pulse: 10th April – EPR Reporting, CE Marked Products & Mercury UV Lamp Exemptions
The Pulse was originally posted on 15th April, 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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This Week’s Trending Sources in C2P
- UK: Placing UKCA or CE marked products on the market in Great Britain, Guidance Document, Revised, April 2026
- Asia Product Compliance: Regulatory Trends in Major Markets in 2025 & 2026
- UK: Placing CE Marked Products on the Market in the EU, Guidance Document, Revised, March 2026
What is Our Content Team Talking About?
US Packaging EPR Reporting: What You Need to Know Before May 31, 2026
by Rúan Doherty, Regulatory Analyst
Producer Reporting Portals
Circular Action Alliance (CAA) has staggered producer reporting portal access across two opening dates:
- March 31, 2026: Oregon, Colorado, California and Minnesota.
- April 23, 2026: Washington and Maryland.
Reporting deadline: May 31, 2026
All producers supplying covered packaging into any of these six states must submit their 2025 supply data to CAA by this date.
- Annual Supply Report: California, Colorado, Oregon
- Full supply data of all covered material categories for 2025.
- Annual Source Reduction Report also due in California.
- Simplified Supply Report: Minnesota, Maryland, Washington
- Streamlined first-cycle reporting for newer programmes, scope and categories are more limited.
Note: In Maine, the Stewardship Organisation (SO) is yet to be selected; once appointed, producers will need to register in May 2026, with the first reporting obligation expected around the same time.
What You Need to Report
Reporting requirements vary by state, but CAA’s producer portal generally requires the following information:
- Total weight or volume of each category of covered material supplied into the state during 2025;
- The methodology used to derive that supply data; and
- Supporting documentation on material classification.
What Are Our Clients Asking About?
The exemption 4.f-IV for mercury UV lamps is set to expire in February 2027. Are there any ongoing legislative discussions about extending this exemption?
Answered by Joyce Costello, Senior Regulatory Compliance Specialist
LightingEurope submitted a request for renewal of Exemption 4(f)-IV in due time on 22 August 2025, and it therefore remains valid until a decision is made on the renewal request. So the 24 February 2027 deadline is now effectively suspended.
The next stage is the start of the technical assessment of the application(s), which will be conducted by Oeko-Institut, when the group of exemptions to be assessed receives a ‘Pack’ number and a stakeholder consultation will be published. The August 2025 exemption applications concerning mercury in lighting will likely be clustered together in one Pack.
I think it is reasonable to expect the publication of the dossiers and commencement of the stakeholder consultation by Oeko-Institut in this quarter.
The next stage involves the consultant publishing their Final Report, which includes recommendations to the EU Commission regarding exemption renewal. The Final Report is the most reliable point at which to assess the likelihood of the Commission extending the exemption, as it usually does not depart too far from the consultant’s recommendation, if at all.
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