The Biweekly Pulse: 9th January – UK Sustainability Reporting Standards, EU Toy Safety Regulation and Brazilian REACH Updates
The Pulse was originally posted on 14th January, 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
- Asia Product Compliance: Regulatory Trends in Major Markets in 2025, Whitepaper, December 2025
- USA: Uniform Packaging and Labelling Regulation, NIST Handbook 130, 2026
- EU: Study on Exclusion of Plastic Pallet Wrappings and Straps from the 100% Reuse Obligations of Transport Packaging in the PPWR, Report, December 2025
What is Our Content Team Talking About?
UK: Government Reiterates Plan to Publish UK Sustainability Reporting Standards in Early 2026 and Outlines Roadmap to Mandatory Adoption
by Hannah Janknecht, Regulatory Compliance Specialist
On 6 January 2026, the UK Department for Business and Trade (DBT) sent a letter to the UK Financial Conduct Authority, outlining the following plans for the implementation and adoption of the UK Sustainability Reporting Standards:
- The government anticipates publishing the final versions of UK SRS S1 and UK SRS S2 early in 2026.
- The DBT intends to incorporate recent International Sustainability Standards Board (ISSB) amendments into the final UK SRS S2. They are also reviewing technical feedback regarding restatements and financed emissions.
- To provide more clarity, the government will remove specific time-references regarding reliefs (transitional exemptions) within the standards. Instead, the timing and availability of these reliefs will be defined by government regulations or FCA rules.
- The DBT acknowledges the FCA’s plan to consult in January 2026 on adopting these standards for listed companies. Both bodies are working to align their approaches since the FCA’s consultation will launch before the final standards are published.
What Are Our Knowledge Partners Talking About?
The New EU Toy Safety Regulation: Changes to the Toy Manufacturing Landscape
by RINA
The European Union’s Toy Safety Directive 2009/48/EC is set to be replaced by the new EU Toy Safety Regulation. Adopted in 2025, the regulation aligns with the EU Chemicals Strategy for Sustainability and strengthens child safety by banning harmful substances, introducing the Digital Product Passport (DPP), imposing stricter obligations on online sellers, and ensuring consistent rules across member states. With approval by the Council of the EU and imminent formal adoption, businesses should prepare for significant changes in how toys are regulated.
What’s Changing?
- Scope of toy products.
- Unlike the directive, the new rules directly apply to all member states, removing national interpretative differences.
- Stricter customs controls.
- The regulation significantly strengthens the prohibition of dangerous substances in toys.
- Promotes the use of DPPs and digital safety assessment obligations.
Scope Changes
Previously excluded toy products (under the directive) such as catapults and slings are now expressly included in scope of the regulation. The scope also extends to digitally connected toys in an effort to ensure that risks posed by internet connected toys are addressed by EU law. The new regulation sets out requirements for radio toys such that they comply with essential requirements for the protection of privacy. Internet connected toys are expected to incorporate safeguards towards cybersecurity and protection from fraud. Toys must not introduce risk to children from the use of digital technologies in toys. As such the regulation now incorporates psychological and mental health factors, as well as the well being and cognitive development of children.
Global Alignment
The EU Regulation will be directly applicable to member states, aligning toy safety with the broader new legislative framework and General Product Safety Regulation. There will be tightened obligations on manufacturers, importers, distributors and online sellers. Organizations must expect consistent enforcement across the EU, reducing scope for local deviations and introducing increased scrutiny of documentation and traceability systems.
The regulation aims to strengthen toy safety rules by implementing the use of DPP containing key information, promoting traceability and customs control. This requirement is similar to the implementation of the digital battery passports, showing a harmonized approach to product safety and market surveillance efforts.
Stricter Customs Control
The introduction of DPPs increases the powers of customs control as importers will need to submit the DPPs at EU borders. This requirement extends to online sellers as toys sold online will be reviewed at EU borders as well. A new IT system will be used to screen all DPPs at the EU’s external borders and will identify the shipments that need detailed controls at customs.
Chemical Changes
The ban on carcinogenic, mutagenic, or toxic for reproduction (CMR) substances is expanded to include endocrine disruptors and chemicals that are toxic to specific organs or affect various bodily systems like skin sensitisers, biocidal products and per-polyfluoroalkyl substances (PFAS).
The intentional use of PFAS and ten dangerous bisphenols in toys is forbidden, with limited exceptions. Allergenic fragrances are banned in toys for young children or those intended to be placed in the mouth, and toys generally cannot have a biocidal function. Maximum limit values for certain substances will now apply to all toys, not just those for children under 36 months.
What Now?
The new rules will fully apply after a 4 and a half year transition period after publication in the Official Journal. Whilst this may seem like a long time, chemical substitutions, DPP implementation and digital safety processes are likely to require increased administrative effort and as such it is advised that businesses plan well ahead of the deadline. The new Toy Safety Regulation represents a decisive shift in stricter chemical regulation, data driven product passports and digital safety requirements. Businesses that invest now in safe chemical use, better data infrastructure and integrated digital risk assessments will be well positioned for the regulation.
What Are Our Clients Asking About?
Is There Already a Brazilian REACH-Like Law Published? If So, Is It Similar to EU REACH and What Is the Implementation Timeline?
Answered by, Valentina Marchetti, Senior Regulatory Compliance Specialist & Team Lead
Yes, a Brazilian REACH-like law has been published. On 14 November 2024, Brazil enacted Law No. 15,022/2024, which establishes the National Inventory of Chemical Substances (INSQ). The law introduces a national framework for the registration, assessment, and risk management of chemical substances manufactured or imported into Brazil.
Under the law, substances manufactured or imported at ≥1 tonne per year, calculated as an average over the previous three years, must be registered in the INSQ. Registration requires substance identification, manufacturer or importer details, volumes, hazard classification under Brazilian standards, and intended uses. Foreign manufacturers may appoint an exclusive representative in Brazil, similar to the EU REACH only representative concept. Mixtures and articles are not registered as such; only the individual substances in mixtures are subject to registration, with additional exemptions for certain polymers.
The law establishes a framework for risk assessment and risk management, allowing authorities to prioritize substances based on hazard and exposure concerns and to impose measures such as labeling and SDS updates, risk reduction plans, prior authorization, or restrictions and prohibitions. However, Brazil does not yet have substance lists equivalent to the EU REACH SVHC Candidate List, Authorisation List (Annex XIV), or Restriction List (Annex XVII). The INSQ will form the baseline list of substances on the market, with restrictions and authorizations to be developed at a later stage.
Implementation is still ongoing. The law requires implementing regulations within 180 days and the development of the INSQ IT system within three years. Once the system is operational, companies will have up to three years to submit their registrations. A draft implementing decree was released for public consultation in May 2025, but registration and enforcement obligations are not yet fully in force.
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