The Biweekly Pulse: 13th February – EU REACH, China RoHS 2, and EU Omnibus Regulatory Simplification Updates
The Pulse was originally posted on 17th 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.
Check out the latest 2026 Regulatory Compliance Updates with The Pulse, your biweekly source for global regulatory insights!
This Week’s Trending Sources in C2P
- State-by-State Comparison: Packaging EPR Legislation Across the US, Guide, February 2026
- State-by-State Comparison: Right-to-Repair Legislation Across the US, Guide, February 2026
- Chemicals Quarterly Q4 2025 Regulatory Update, Webinar Presentation, January 2026
What is Our Content Team Talking About?
EU Omnibus Regulatory Simplification of Energy Efficiency Product Legislation
by Michelle Walsh, Senior Team Leader
On 12 February 2026, the EU Commission published a consultation on a call for evidence for an impact assessment looking at simplifying energy efficiency product law.
This Omnibus regulatory simplification proposal will focus on making compliance simpler and more effective through targeted amendments on energy-efficient product legislation. Targeted amendments will focus on:
- Reducing administrative complexity e.g. on how to deliver (printed) labels and printed product information sheets;
- Streamline registration / compliance with the European Product Registry for Energy Labeling (EPREL) product database;
- Better inform consumers through product-specific labels to make informed purchasing decisions (.ie for heating & cooling and tyres);
- Simplifying the tyre label requirements to changes in technology or market conditions.
The purpose of the consultation is to find out whether the currently identified option can be accepted by stakeholders, whether there are additional simplification ideas and to receive information that could help quantifying benefits.
Interested stakeholders are invited to comment on this consultation until 12 March 2026.
What Are Our Experts Talking About?
EU REACH: An EU Study Recommends Exempting Critical Industries From Upcoming PFAS Restrictions
by Dieudonné Ymedji, Senior Regulatory Compliance Specialist
A recent study commissioned by the European Parliament’s Committee on Industry, Research and Energy (ITRE) highlights the complex trade-offs between regulating “forever chemicals” (PFAS) and maintaining Europe’s industrial competitiveness.
The findings are stark:
- PFAS are currently essential in key sectors like aerospace, defence, and semiconductors.
- A full or partial ban on PFAS could cost over €560 billion in the first year and impact millions of jobs across the EU, with SMEs being the most vulnerable.
- The EU’s global competitiveness could be at risk if viable alternatives are not available.
Policy Recommendations Analysis
The study concludes that implementing blanket PFAS restrictions would be economically damaging and technically unfeasible across several critical sectors. Instead, it advocates a sector-specific approach with tailored derogations.
- For the aerospace and defence industry, permanent or long-term derogations are recommended, with reviews every 10 to15 years. This reflects the lack of viable alternatives and the sector’s paramount safety and security requirements. The study also calls for funding innovation and conducting supply chain studies.
- Regarding the semiconductor sector, a permanent derogation is proposed, highlighting the sector’s essential role in the digital economy and artificial intelligence. The study suggests integrating PFAS management into the European Chips Act and funding abatement technologies.
- A detailed, case-by-case review of derogations is advised for green energy and clean technology, as the potential for substitution varies widely. The report recommends forming a dedicated task force to monitor alternatives and imposing strict emission controls on companies.
- Lastly, the study suggests excluding F-gases from the PFAS restriction and regulating them solely under the existing F-gas Regulation. This would allow for a more gradual transition.
What Lies Ahead?
The study provides a critical evidence base for upcoming political and regulatory decisions on the proposed EU PFAS restriction. The path forward will require careful negotiation to ensure that Europe’s green ambition does not come at the cost of its industrial foundation and strategic autonomy.
What Are Our Clients Asking About?
Are Electrical and Electronic Products As Part of Complex Assemblies in Scope of China RoHS 2?
Answered by Joyce Costello, Senior Regulatory Compliance Specialist
China RoHS 2 covers electrical and electronic products (EEPs) dependent on electric current or electromagnetic fields to work, or to generate or transmit current and are designed for use with a voltage rating not exceeding 1000 Volt for alternating current and 1500 Volt for direct current and its complementary products. Complementary product refers to modules, components, parts and materials of electrical and electronic products. This includes both standard and optional accessories for electrical and electronic products, as well as spare parts used for repair, renovation, expansion or upgrade of electrical and electronic products. It therefore encompasses a very broad range of products including, among others, communications equipment, broadcasting equipment, computers and other office equipment and electrical and electronic products for industrial use. Products in scope are not delimited by HS code.
Obligations under China RoHS fall within 2 types. On the one hand, all EEPs satisfying the above definition are required to declare information of hazardous substances contained in them. Most EEPs fall under this category. Disclosures must be made in accordance with SJ/T 11364-2024.
Products which are listed in the ‘Compliance Management Catalogue’ must declare information, but must additionally comply with hazardous substances limits set out in national and industrial standards. A limited list of products only are subject to the more stringent requirement: refrigerators, air conditioners, washing machines, electric water heaters, printers, copiers, fax machines, televisions, monitors, microcomputers, mobile communication devices, telephones.
So yes, electrical and electronic products, including those which are part of complex assemblies are in scope (provided that they satisfy the basic EEP definition).
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