The Biweekly Pulse: 24th April – Supply Chain Security in China, UK Product Safety and EU PFAS Updates

The Pulse was originally posted on 29th 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

1. EU: Battery Technology in the European Union: 2025 Status Report on Technology Development, Trends, Value Chains and Markets, Report, April 2026
2. Forever Chemicals, Finite Timelines: Managing PFAS Reporting and Compliance Across Borders, Guide, April 2026
3. USA: Draft Risk Evaluation of 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-Hexamethylcyclopenta [g]-2-Benzopyran (HHCB) and Phthalic Anhydride under the Toxic Substances Control Act (TSCA), Notice, 91 FR 19134, 2026

What is Our Content Team Talking About?

China Issues New Security of Industrial and Supply Chains Regulations: Potential Restrictions on Compliance with Foreign Supply Chain Laws

by Hannah Janknecht, Senior Regulatory Compliance Specialist

China published the following regulations on supply chain security in April 2026:

• Regulations of the State Council on the Security of Industrial and Supply Chains, State Council Order No. 834
• Regulations on Countering Foreign Improper Extraterritorial Jurisdiction of the People’s Republic of China, State Council Order No. 835

Content of the Regulations

Order No. 834 sets out a legal framework for China to monitor, protect, and retaliate against threats to its domestic and international supply chains.

The regulation creates a new cross-departmental mechanism involving diplomacy, industry (MIIT), state security, finance, and customs to manage supply chain security. It furthermore enables the state to define “critical areas” and maintain a dynamic list of essential raw materials, technologies, and products, as well as an early warning system to identify supply disruptions and alert the government. If supply chain security is threatened, the government can take emergency measures, including emergency dispatching, utilizing reserves, and organizing mandatory production or transportation.

The law furthermore grants the government power to investigate and punish foreign countries or organizations that impose discriminatory or restrictive measures against Chinese supply chains.

Order No. 835 on the other hand forms a broader blocking mechanism against foreign laws and measures that China deems an improper application of extraterritorial jurisdiction. Based on this, the government will identify foreign measures that violate international law or infringe on Chinese sovereignty and interests. Foreign organizations or individuals who drive or participate in these improper measures can be placed on a “Malicious Entity List”, potentially facing asset freezes, visa denials, bans on investing in China, and restrictions on trade or cooperation with Chinese parties. The order furthermore allows the government to prohibit or restrict Chinese organizations and individuals from providing data or personal information to entities on the Malicious Entity List.

What Does This Mean for Companies?

Both regulations do not mention any foreign laws by name, but they provide several mechanisms that indirectly and explicitly restrict Chinese companies from complying with foreign laws if they are deemed harmful to Chinese interests.

Article 13 of Regulation No. 834 states that any organization or individual that conducts “investigations or other information collection activities” related to supply chains within China in violation of Chinese laws and regulations will face legal action. While the regulation does not define the activities concerned by this, the prohibition could potentially include data collection for ESG reporting and supply chain due diligence purposes. 

Article 14 to 16 furthermore create a connection with the Anti-Foreign Sanctions Law. If a foreign transparency law is classified as a “discriminatory prohibition or restriction” that violates international law, the State Council can conduct a security investigation. Once the government issues a countermeasure, such as a ban on exporting certain data or products to a specific foreign region, domestic organizations and individuals must execute these measures. If a Chinese company tries to comply with a foreign law instead of the Chinese counter-measure, the Chinese government can ban them from government procurement, restrict their imports and exports, or even prevent their personnel from leaving the country. The law however does not define terms such as ‘discriminatory prohibition’, causing uncertainty in how companies are supposed to interpret these provisions in relation to their compliance decisions. 

In addition, the law emphasizes that companies must ensure that data and information systems related to core technologies are secure and controllable. Article 16 specifically lists the provision of data and personal information to overseas parties as something that can be prohibited or restricted if it conflicts with China’s supply chain security measures.

Similarly, Order No. 835 does not explicitly name specific foreign laws. Instead, it provides a set of criteria and a procedural framework that the Chinese government will use to identify and list such laws through future public announcements. Factors to be taken into account include violation of international law and harm to Chinese sovereignty and development interests, or damages to the legitimate rights and interests of Chinese citizens or organizations.

What Are Our Knowledge Partners Talking About?

UK Product Safety Overhaul: OPSS Consults on Core Framework Reforms and New Enforcement Toolkit

by Cooley

The UK’s Office for Product Safety and Standards (OPSS) published two consultations proposing sweeping reforms to the UK product safety framework. In this blog, the Cooley products team considers the key proposals – from an expanded scope and new online marketplace duties to digital labelling flexibility and a consolidated enforcement toolkit featuring civil monetary penalties – and flags why they could be important to you.

On March 31, 2026, the UK’s national product safety regulator, the Office for Product Safety and Standards (OPSS), published its long-awaited consultations setting out proposals to reform the UK product safety framework. The proposals are split across two consultations – one on the framework itself and one on enforcement:

1. Product regulation: the UK’s new product safety framework  
2. Product regulation: market surveillance and enforcement framework  

Why Does This Matter?

These proposals form part of a programme of work intended to deliver the most significant overhaul of the UK product safety framework in a generation. The consultations offer stakeholders a real opportunity to advance issues, such as digital labelling, and to advocate for simplification and reduced business burdens. For some topics, this may be the only chance to provide input before secondary legislation is introduced under the Product Regulation and Metrology Act 2025 (PRAM Act). For potentially impacted businesses, now is the time to engage – either to voice support or concern, or propose clarifications.

Headlines of What’s Included in the Proposals

Getting the basics right

EU alignment: Northern Ireland (NI) will continue to follow certain European Union product safety rules in accordance with the Windsor Framework. The consultation notes that the new UK framework is expected to apply in Great Britain (GB) in a complementary way to EU rules applying in NI, and that UK proposals will “support trade with the EU”, all pointing to some level of EU alignment. However, several proposals envision a different approach to that of the EU – in short, we see the potential here for a level of conflict and confusion.   

Reforms to core framework rules: The first consultation addresses the UK’s product safety framework, proposing reforms to the rules in the UK’s General Product Safety Regulations 2005 (UK GPSR). The UK GPSR acts as a baseline “safety net”, where there are no specific provisions with the same objective in other product safety legislation. This consultation will be followed by reviews of sector-specific legislation (i.e. governing UKCA/CE-marked products) that overlay the core framework, to be carried out over the next three years. Whatever is agreed in the core framework will therefore have far-reaching implications. 

Expanded scope: A key proposal is expanding the UK GPSR beyond consumer products to cover all products, including non-consumer workplace products, with some exemptions. This is a wider scope than the EU GPSR (focused on consumer products); however, it is not seeking to cover stand-alone software (which EU GPSR does, albeit not expressly within the legislation itself; this is instead confirmed in guidance). As with the EU regime, sector-specific legislation with the same objective would continue to take precedence over the new baseline framework. Arguably, the category of non-consumer workplace products not already covered by sector-specific legislation is likely to be very narrow. However, the proposals could still affect these products where they introduce new pre-market or post-market obligations not addressed by existing sector-specific regimes.

Updates for new technology products: The proposals include updating the factors relevant for assessing product safety, including cybersecurity and artificial intelligence/machine learning risks – broadly in line with the EU GPSR’s broadened view of “safety”.  

Accountability Throughout the Supply Chain

Reframed supply chain actors bringing online marketplaces into view: The consultation proposes duties for three categories of supply chain actor:

1. “Producers” (UK-based manufacturers/own-branders, UK-authorised representatives, importers, overseas sellers for distance sales direct to UK consumers, and others whose activities affect product risk)
2. “Onward suppliers” (distributors and fulfilment service providers)
3. “Online marketplaces”

For online marketplaces, the proposals include new duties to act with due care to prevent, identify and remove dangerous products, and to practise due diligence to identify and take action against “bad actors” on their platforms. These are framed as high-level, outcomes-based duties – giving marketplaces flexibility in how they comply aligned with their activities and role in the supply chain. The consultation includes non-exhaustive examples of compliance steps but does propose mandating verification of seller contact details. These duties sit alongside other targeted reforms, including requiring online marketplaces to design their interfaces to enable third-party sellers to comply with new mandatory information requirements for online offers.

Additional tools to manage higher-risk products: The consultation proposes additional tools for higher-risk products, including potential verification or pre-listing assurance requirements for onward suppliers (i.e. distributors) and online marketplaces. It also proposes that there be a UK-based responsible person for the GB market, but only for certain high-risk products, e.g. where many of the noncompliant goods in question enter the GB market from abroad. This contrasts with the EU and NI position, which requires an EU responsible person for all non-harmonised products in scope of the EU GPSR and for products under many EU sector-specific rules. The UK approach recognises that requiring a responsible person for all products would not be proportionate. However, the role would be limited to UK-based manufacturers, authorised representatives or UK importers – without the option of using a fulfilment service provider (as is available in the EU).

Post-market monitoring, corrective actions and reporting: The consultation proposes requirements on product safety monitoring and corrective actions for all supply chain actors (producers, onward suppliers and online marketplaces), with the extent of the obligation depending on their respective activities within the supply chain. It also proposes requirements to retain documentation to enable product traceability. Overall, the proposals appear largely to preserve the existing recall and reporting framework, while introducing some additional obligations – notably for online marketplaces. However, the consultation does not provide detail on whether specific reforms introduced under the EU GPSR (for example, in relation to recall remedies) will be taken forward in the UK.

No mention of accident reporting: At this stage, the consultation gives no indication that OPSS intends to follow the EU GPSR approach of introducing a separate general accident reporting obligation (outside of the risk-based obligation to report dangerous products and existing obligations to report certain incidents for specific products, e.g. cosmetics). 

Cooperating with authorities: The consultation proposes extending the statutory duty to cooperate with authorities to all supply chain actors. Online marketplaces may be required to enable access to their interfaces for online tools operated by regulators to identify noncompliant products. The proposals also include requiring producers and online marketplaces to have a single point of contact for authorities, with online marketplaces potentially required to register this contact point.

A New Approach to Product Information

Move towards greater digital and physical labelling flexibilities: The consultation proposes allowing certain product information to be provided digitally instead of physically, as part of a broader push towards “digital by default”. At this stage, the proposals cover the producer’s name and contact details (capturing the UK importer) and even certain safety-relevant information. For UKCA/CE-marked products (governed by sector-specific legislation), the government has announced that separate legislation is planned for later this year to give businesses more flexibility on labelling for products placed on the GB market, including allowing digital labelling for some information – albeit for anyone placing the same products also on the EU and NI markets, digital labelling alone, for the most part, will not be compliant as things currently stand (the EU has been consulting on potential proposals as part of the upcoming European Product Act, largely focussed on moving towards Digital Product Passports).  

New requirements for online offers: The consultation also proposes new mandatory information requirements for online product offers, largely based on the EU GPSR but arguably going further – including compliance markings and “any other information that could inform the purchase of a product”, such as whether a product uses AI or includes AI-driven features.

Building on the New Foundations

Consolidating and simplifying the regulatory landscape: Ahead of the sector-specific reviews, the consultation also seeks feedback on provisions in sector-specific legislation that could be simplified, moved to the core framework, delivered through standards, replaced by guidance or removed entirely.

Preparing for products of the future: The consultation focuses on AI components in physical products (excluding AI in its own right). No specific reforms have been proposed at this stage. Instead, the OPSS is seeking feedback to inform future proposals and its upcoming sector-specific reviews about, for example, current or potential harms associated with AI-enabled products, regulating life cycle risks, and how to regulate AI-enabled products and digital innovations while supporting innovation.

Market Surveillance and Enforcement Reform

New enforcement toolkit: The second consultation proposes consolidating and strengthening enforcement and market surveillance powers currently spread across more than 71 pieces of legislation into a single toolkit in one piece of legislation, applicable across all product regulation (UK GPSR and sector-specific legislation).

Expanding available penalties to ramp up enforcement: The existing reliance on criminal sanctions is seen as a blocker to enforcement (due to higher bar and the time and costs to bring criminal proceedings). The consultation proposes introducing civil sanctions, including powers for authorities to directly issue civil monetary penalties, alongside tools like enforcement undertakings (similar to the new enforcement regime under the Digital Markets, Competition and Consumers Act 2024 (DMCCA)). The OPSS is also considering obligations for companies to admit fault publicly or pay compensation.

In relation to online marketplaces, the OPSS is considering whether additional bespoke enforcement powers are needed, such as powers similar to Online Interface Orders available in the EU and under the UK DMCCA (e.g. directing removal of content, disabling access, displaying warnings or deleting domain names) or requiring certain online marketplaces to have a UK presence (e.g. where they have a high number of UK sales or demonstrated noncompliance or lack of cooperation with authorities).

Other reforms to enhance market surveillance: Proposals include new cost recovery powers for authorities and enhanced information sharing.

What’s Next?

Both consultations are open until June 23, 2026. This is an important opportunity for stakeholders to comment on the proposed reforms. After considering stakeholder responses, the government plans to publish its response within 12 weeks and to introduce regulations in Parliament to implement the decisions taken. The government then plans to complete the sector-specific reviews over the next three years.

In addition to the two main consultations, the OPSS has separately published a third consultation on the fire safety of domestic upholstered furniture.

What Are Our Clients Asking About?

Could You Please Provide an Overview of the PFAS-Related Regulatory Framework in the EU?

Answered by Dieudonné Ymedji, Senior Regulatory Compliance Specialist

The European Union currently has a diverse set of regulations for managing PFAS beyond the core EU REACH and POPs regulations. These regulations include restrictions on specific PFAS compounds such as PFOA, PFOS, PFHxA, long-chain PFCAs and PFHxS.

The recast Drinking Water Directive sets a maximum of 0.1 µg/L for the sum of 20 specific PFAS and 0.5 µg/L for the total concentration of all PFAS, with mandatory monitoring since January 2026.

From 12 August 2026, the Packaging and Packaging Waste Regulation 2025/40 imposes strict limits on PFAS in food packaging, with a focus on paper and cardboard materials.

Starting 1 August 2030, the Toy Safety Regulation 2025/2509 will prohibit the use of hazardous substances in toys as soon as they are identified as harmful, including PFAS.

The European Chemicals Agency is also currently finalising a comprehensive restriction proposal for all PFAS, with final opinions expected by the end of 2026. This is likely to result in a phased ban across most uses, with sector-specific transition periods.

At the national level, Denmark’s Executive Order BEK No. 464 of May 2025 bans PFAS in clothing, footwear, and waterproofing agents used in consumer products, effective 1 July 2026, with an inventory sell-off permitted until 1 January 2027.

France’s Law No. 2025-188, enacted in February 2025 and effective from January 2026, bans PFAS in cosmetics, textiles, and ski waxes. All textiles must be PFAS-free by 2030. The law also introduces a €100 tax for every 100 g of PFAS discharged, requires monitoring of drinking water, and aims to achieve zero industrial PFAS water emissions by 2030.

Unlike Denmark and France, no other EU member states are currently considering broad bans on PFAS in consumer products. However, in Belgium, a bill introduced in March 2025 aims to prohibit PFAS in food contact materials, cosmetics, and textiles from January 2026, with limited exemptions for essential applications. The bill’s approval in parliament is still pending.

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