The Biweekly Pulse: 14th March – EU Batteries Regulation, Forced Labor Import Bans, and Chemicals Updates

The Pulse was originally posted on 18th March, 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

1. EU Omnibus Simplification: Essential Regulatory Insights for Global Manufacturers, Guide, March 2026
2. France’s PFAS Decree Explained: Key Questions for Manufacturers and Importers, Blog, March 2026
3. State-by-State Comparison: PFAS in Products Legislation Across the US, Guide, March 2026

What is Our Content Team Talking About?

USTR Launches Investigations into Forced Labor Import Bans Across 60 Economies

by Cristian Barroso, Regulatory Compliance Specialist

The United States Trade Representative (USTR) has initiated investigations into 60 economies – including Australia, the UK, the EU, Canada, and Mexico – to assess whether they effectively prohibit and enforce bans on the importation of goods produced with forced labor. As part of this process, USTR opened a public consultation period to gather stakeholder input on several issues, including:

• The existence and enforcement of each country’s prohibition on the importation of goods produced with forced labor.
• The extent to which a country’s failure to prohibit or effectively enforce such bans affects U.S. commerce.
• Potential actions to address these concerns, such as possible import restrictions on products from economies under investigation.
• The appropriate aggregate level of trade that could be subject to additional duties on products from economies covered by these investigations.

A pre-publication version of the Federal Register notice is available here.

The dockets for submitting comments regarding the investigation and requests to appear at the public hearing associated with this investigation are available here.

More information is available on the USTR website.

What Are Our Knowledge Partners Talking About?

IEC 62474 Updates DSL and Exemption List – 2026 March

by ECD Compliance

The IEC 62474 declarable substance list (DSL) was updated to Version D32.00 on March 6, 2026. The International Standard for material declaration for the electrical and electronics industry includes the EEE industry DSL, material declaration data exchange requirements and format, material classifications and exemption lists. The parts of the standard that require periodic updates (such as the lists) are published online in the IEC SDB 62474 database and are updated using an expedited IEC SDB process. 

Declarable Substances List (DSL)

The IEC 62474 SDB Team has prepared an extensive update to the DSL. The new entries are listed in Table 1. This includes DBDPE which ECHA rushed onto the REACH Candidate List on November 5, 2025 and one of the two SVHC added to the Candidate List on February 4, 2026. The SDB Team for IEC 62474 did not find any evidence that the other SVHC (n-hexane) would be contained in a EEE product above the 0.1 mass%, therefore the substance was not added to the DSL – it was added to the REACH complementary list that is posted on the SDB. 

Two new entries were also added for PFHxA, its salts and related substances which was added to the REACH Annex XVII list of restricted substances. Note: the Annex XVII entry was split into two entries for the DSL due to different reporting thresholds for PFHxA and its salts versus PFHxA related substances.

Table 1: Entries Added to the DSL

Four existing entries in the DSL were modified as shown in Table 2.

• The mercury/mercury compounds entry (00029) was an editorial only update to the basis description – adding the [Japan] Act on Preventing Mercury Pollution of the Environment
• The phthalates entry (00036) broadened the scope to all applications
• The PBDE entry (00045) now has a reduced reporting threshold from 0.1% to 0.001% due to the addition of the substance to the EU POPs regulation.
• The halogenated flame retardants entry (00171) has an expanded scope that now includes all plastic external enclosures and stands. The reporting threshold was also updated to include intentionally added.   

Table 2: Changes to Existing DSL Entries

Reference Substances List (RSL)

Nine reference substances were added for the declarable substance group BPAF and its salts; two were added for PFHxA and its salts, and 89 reference substances for PFHxA-related substances. 

IEC 62474 – Exemption List for EU RoHS Annex III

The IEC 62474 SDB (database) also contains structured and organized representations of the EU RoHS exemption lists (EL). The IEC 62474 Annex III exemption list (ID=EU-RoHS-AnnexIII) has been updated to reflect the outcomes of the renewal requests for exemptions 6(a), 6(a)-I, 6(b), 6(b)-I, 6(b)-II, 6(c), 7(a), 7(c)-I and 7(c)-II. The revised exemptions and expiry dates are specified in the three Delegated Directives that were published in December 2025. 

Note: the IEC 62474 SDB Team identified an ambiguity in Delegated Directive (EU) 2025/2364 for exemption 6(b) Lead as an alloying element in aluminium. The existing exemption was only applicable to category 8, 9, and 11 products. However, the new entry in the Delegated Directive does not specify any product categories. The SDB Team made the assumption that the European Commission intended the exemption to only apply to categories 8, 9, and 11; therefore, this was implemented in the update.

Additional Information

The IEC 62474 DSL/RSL, exemptions lists, data exchange format (DXF), and other parts are available online from the IEC 62474 database: https://std.iec.ch/iec62474/iec62474.nsf/index 

The new entries in the DSL and RSL have a last revised date of 2026-02-22. 

Future Updates to the DSL

The SDB Team is working on several further updates to the DSL including new Critical Raw Material (CRM) entries for emerging EU ecodesign implementing measures and POPs entries based on the Stockholm Convention. 

What Are Our Clients Asking About?

Under the EU Batteries Regulation, What Are the Compliance Deadlines for the Carbon Footprint Declaration and the Battery Passport?

Answered by Dila Şen, Senior Regulatory Compliance Specialist

Under Regulation (EU) 2023/1542 on batteries and waste batteries, the timeline for the carbon footprint declaration is governed by Article 7(1). For rechargeable industrial batteries (except those with exclusively external storage), the obligation applies from 18 February 2026 or 18 months after the entry into force of the delegated and implementing acts establishing the methodology and format for the declaration, whichever is later.

The battery passport requirement, on the other hand, applies from 18 February 2027 for industrial batteries with a capacity above 2 kWh pursuant to Articles 13, 77 and 96 of the Regulation.

In practice, the battery passport functions primarily as a data carrier. Therefore, it must contain the carbon footprint information only once the carbon footprint declaration obligation under Article 7 becomes applicable. If the 18-month transition period triggered by the relevant delegated and implementing acts extends beyond February 2027, the battery passport may initially be issued without carbon footprint data, which would then need to be incorporated once the Article 7 obligation takes effect.

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