The Biweekly Pulse: 25th August – 5th September – German Supply Chain Due Diligence Act, K-RoHS and Ecodesign Updates
The Pulse was originally posted on 10th September, 2025. 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 2025 Regulatory Compliance Updates with The Pulse, your biweekly source for global regulatory insights!
This Week’s Trending Sources in C2P
- Certification, Due Diligence and Declarations: Legal Instruments Addressing Deforestation and Illegal Logging in Global Supply Chains, Whitepaper, September 2025
- South Africa: National Policy for the Management of Waste Electrical and Electronic Equipment, Policy Document, 2025
- Product Compliance in Fashion & Textiles: Navigating New Rules on Labelling, Ecodesign & Environmental Claims, Webinar Presentation, August 2025
What is Our Content Team Talking About?
German Ministry of Labor Proposes to Remove Reporting Obligations from German Supply Chain Due Diligence Act (LkSG)
by Hannah Janknecht, Regulatory Compliance Specialist
On 29 August 2025, Germany’s Ministry of Labour and Social Affairs published a draft amendment to the Supply Chain Due Diligence Act (LkSG):
- Reporting: The draft proposes to remove the Act’s reporting requirements, meaning companies will no longer need to publicly report their on the due diligence measures they have taken.
- Fines: The draft proposes to revise the provisions on fines to prevent companies from being overburdened during the transition before the EU Corporate Sustainability Due Diligence Directive (CSDDD) is adopted into German law. Fines shall only apply in case of failure to implement preventive and/or remedial measures or failure to implement a grievance mechanism, which are considered to be severe violations.
- Timeline: The amendment would take effect immediately after promulgation, with certain provisions (Articles 1.1–1.4) applying retroactively from 1 January 2023.
There are no proposed amendments to the Due Diligence obligations and, as such, if the proposal is finalized, companies would still be required to carry out due diligence, identifying supply chain risks, taking preventive and corrective actions, and maintaining grievance mechanisms.
What Are Our Knowledge Partners Talking About?
Smartphones and Tablets Now In Scope for Ecodesign. What Do You Need to Know?
by RINA
As of 20 June 2025, Ecodesign requirements for smartphones and tablets are now mandated by the EU as part of efforts to ensure product longevity and the reduction of electronic waste. Commission Regulation (EU) 2023/1670 sets ecodesign requirements for smartphones, mobile phones other than smartphones, feature phones, cordless phones and slate tablets placed on the EU market. They must meet specific design and information requirements that promote durability, repairability, and environmental transparency. For suppliers using these devices in their systems, it’s important to ensure that any units sourced or integrated are compliant, as non-conforming devices may pose supply chain risks or fail to meet public procurement requirements.
How to Comply?
The regulation requires that devices are built to withstand water, dust, and accidental drops, and that critical spare parts (such as batteries, displays, and mechanical buttons) are made available for at least seven years after the product is no longer sold. This is particularly important for companies relying on devices deployed in professional or industrial settings, where ongoing functionality is essential. Devices must also be designed for repairability, meaning disassembly and battery replacement should be possible using common tools, without damaging the device.
For those placing smartphones or slate tablets on the EU market (whether under their own brand or as part of a larger product assembly, additional obligations apply. These include publishing information on battery life, recyclability rate, recycled content (if known), and critical raw materials used, as well as IP ratings for resistance to dust and water. Some of this data must be made accessible to the public, not just service providers, to improve transparency and user awareness.
Importantly, a draft amendment to Regulation (EU) 2023/1670 (Draft Commission Regulation correcting Commission Regulation (EU) 2023/1670, notification date: 15 April 2025) correcting misleading language in the legislation has been published and it clarifies that display repairability will not be in scope as a layperson cannot conduct this type of repair. With industry groups, consumer advocates, and repair coalitions (like Right to Repair Europe) continually pushing for stronger repairability rights, this kind of amendment reflects the Commission’s responsiveness to stakeholder feedback and technical realities. As such, RINA expects there may be further amendments or guidance documents issued in the future.
What is Next?
Businesses that manufacture, integrate, distribute, or rely on these devices should begin preparing now. That means confirming the compliance status of suppliers, ensuring that technical files and spare parts stock provisions are in place, and updating internal guidelines on the procurement of in-scope devices. This regulation supports longer-lasting, safer, and more sustainable product strategies.
What Are Our Clients Asking About?
In South Korea, is Industrial Equipment Excluded From the Proposed Expanded Scope of K RoHS?
Answered by Joyce Costello, Senior Regulatory Compliance Specialist
The revised provisions of Article 8(1) will commence on 1 January 2028, including the expanded scope. According to the amendment, electrical and electronic products used as industrial equipment and large-scale fixed facilities, will be determined and announced by the Minister of Environment.
The current exclusion covers large fixed industrial equipment and large fixed facilities, and conditions have been prescribed to determine whether or not it can be claimed.
Specifically:
- Electrical and electronic products that meet all of the following conditions are recognized as large fixed industrial equipment and large fixed facilities:
A. Multiple types of equipment or devices are assembled or combined to form a single device or facility
1) Large fixed industrial equipment: Equipment weighing 2 tons or more and measuring 15.625㎥ or more (e.g., 2.5m × 2.5m × 2.5m).
2) Large fixed equipment: Equipment that meets any of the following requirements and requires structural improvement work, such as ground reinforcement work or drive-in work, for installation.
- a) When transporting for installation or dismantling, the total number of parts exceeds the size of an ISO20 container (5.9m × 2.35m × 2.39m).
- b) When transporting for installation or dismantling, more than one large cargo truck (25 tons) is required.
- c) For installation or dismantling, a large crane that meets any of the following requirements is required:
- (1) Cranes defined in Appendix 1, No. 7 of the Enforcement Decree of the Construction Machinery Management Act, with a lifting capacity of 25 tons or more and a working radius exceeding 12 meters.
- (2) Tower cranes defined in Appendix 1, No. 27 of the Enforcement Decree of the Construction Machinery Management Act. A maximum rated load of 25 tons or more and a working radius exceeding 12 meters.
- (3) A crane device attached to a freight vehicle (special-purpose type) as defined in Appendix 1, No. 2 of the Enforcement Regulations of the Automobile Management Act, with a lifting capacity of 25 tons or more.
- d) A product with a rated output of 375 kW or more.
B. Assembly, installation, and disassembly of large equipment or facilities require the work of relevant experts
1) A relevant expert is a person who has received appropriate training or skill to perform the relevant work.
2) Assembly, installation, and dismantling operations each require an equivalent level of skill. Dismantling by a demolition company is not recognized.
C. Equipment or facilities that are permanently installed and used in a specific space
1) Equipment or facilities intended for permanent installation in a building or structure.
2) If moved from the initial installation location for the purpose of implementing product functions, etc., they are not considered fixed installations. However, if they are mobile, such as moving on a fixed rail due to the specific nature of the work, they are considered fixed.
D. Large fixed equipment is recognized only if it can be replaced with identically manufactured, specialized equipment
1) If replacement is necessary, it must be manufactured specifically to meet custom specifications (e.g., design, size, structure, etc.).
2) If a standardized or non-customized product (a) is combined with a large device or equipment (b) that qualifies as exempt, the product (a) will not be considered an exception to the large device or equipment category.
E. Used in industrial manufacturing facilities
This only applies to business-to-business (B2B) transactions involving equipment or facilities used in industrial manufacturing facilities. It does not apply to equipment or its parts used in business-to-consumer (B2C) transactions.
It remains to be seen whether or not these conditions will be revised before 1 January 2028, considering the reference to “will be determined and announced by the Minister of Environment.”
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