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What’s Trending in Compliance? September 2025

Sep 22, 2025 What’s Trending in Compliance? September 2025

This blog was originally posted on 22nd 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.


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Below we break down some of the top compliance trends in September 2025 that are generating the most interest globally this month.

1. Singapore: Requirements for Equipment Containing Hydrofluorocarbon (HFC) Refrigerants, Consultation Paper, September 2025

On 8 September 2025, the Singapore National Environment Agency (NEA) published a consultation paper on requirements for equipment containing hydrofluorocarbon (HFC) refrigerants.

The proposed requirements include the introduction of GWP limits on the supply of new standalone commercial refrigerators (≤150g charge), centralized commercial refrigeration systems, and passenger cars and light goods vehicles (LGVs) as well as the mandatory on-site recovery of refrigerants covered during the commissioning of centralized commercial refrigeration systems, centralized industrial refrigeration systems for cold rooms, passenger cars and LGVs, and refrigerated trucks.

The sale of new equipment and vehicles covered containing HFC refrigerants that do not meet the global warming potential (GWP) limit of 150 is proposed to be banned. Covered new equipment will also need to be registered under the Environmental Protection and Management Act (EPMA). The proposed mandatory on-site recovery shall apply to refrigerants with GWP of more than 15. Companies involved in the installation, maintenance or decommissioning work are also proposed to register with the NEA as a greenhouse gas entity and maintain and submit records of regulated greenhouse gas work quarterly.

The requirements are proposed to be implemented from 1 April 2027. Companies will be given a one-year grace period to clear existing stocks and fulfill predetermined obligations for the supply of covered equipment and vehicles covered containing HFC refrigerants that exceed the 150 GWP threshold.

On 20 August 2025, the Guidance for businesses trading in timber and timber-related products was updated.

The Guidance mentions that the European Timber Regulation (EUTR) and Forest Law Enforcement Governance and Trade (FLEGT) no longer apply in Great Britain (England, Scotland and Wales). The Timber and Timber Products Placing on the Market Regulations (UKTR) and UK FLEGT Regulations apply in Great Britain from 1 January 2021 but the requirements remain the same as under EUTR.

Timber imported from countries that have implemented voluntary partnership agreements (VPAs) with the UK – currently only Indonesia – must be accompanied by a FLEGT licence. Businesses shall ensure that timber and timber products originate from legal sources. 

There are two separate regulatory regimes:

  • The UK Timber Regulations
  • The FLEGT Regulations

Each of these regulatory regimes consists of a suite of separate regulations, which are mentioned in the guidance document.

3. EU: Towards a Restriction of Chromium(VI) Substances Under REACH, Questions and Answers, August 2025

These questions and answers, revised by the EU Commission in August 2025, provide an overview of the ongoing restriction process of chromium (VI) substances under EU REACH, and their current status. The revised text includes some initial considerations on the transition from authorization to restriction for Cr(VI) substances. 

The document clarifies the reasons behind the Commission’s intention to request ECHA to prepare a proposal for a possible restriction on chromium (VI) substances. It also offers some clarification on: 

  • What is the intended scope of the restriction
  • How will it account for chromium (VI) substances that have already received authorization, and
  • How the Commission and ECHA plan to handle applications for and authorizations of chromium(VI) substances that might be affected by the future restriction while the restriction is still not in place

Companies dealing with Cr(VI) compounds are encouraged to consult the document for more information. 

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4. California (USA): Senate Bill 54 Covered Material Categories (CMCs), Updated List, September 2025

Public Resources Code (PRC) section 42061(a)(1) required California Department of Resources Recycling and Recovery (CalRecycle) to establish and post a list of material categories covered by the Plastic Pollution Prevention and Packaging Producer Responsibility Act (Senate Bill (SB) 54) by 1 July 2024. As defined in PRC section 42041(f), covered material categories (CMCs) are categories that include covered material of a similar type and form, as determined by the department.

This document provides an update of CMCs relative to the 31 December 2024 version, and does not include an update to determinations of recyclability or compostability. CalRecycle updates the recyclability and compostability determinations annually to meet requirements of PRC section 42061(e).

The table in this document is an updated list of 95 CMCs. A summary of changes made since the prior publication is provided at the end of the document.

5. South Africa: National Policy for the Management of Electrical Waste and Equipment, Policy Document, August 2025

On 29 August 2025, the South African Department of Environment, Forestry and Fisheries published the finalized National Policy for the Management of Waste Electrical and Electronic Equipment (“WEEE”).

The WEEE Policy calls for setting up a clear regulatory and institutional framework based on the principles of extended producer responsibility (“EPR”), with clear roles and responsibilities laid down in law and underpinned by a financing system required for the environmentally sound management of e-waste. The WEEE Policy document sets out the framework, defines the key policy aims and describes the suggested objectives and expected outcomes required for South Africa in order to harness opportunities together with ensuring the protection of the population and the environment.

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The top compliance trends in September 2025 is based on the most viewed regulations on C2P this month. If you would like to see C2P in action, join us for a bite-sized high-level demo to witness the true power behind C2P.

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