Upcoming changes

2 rules in Proposition 65 list of chemicals known to the State to cause cancer or reproductive toxicity (27 CCR 27001), OEHHA list, for products sold, from 8 Dec 2026. Applies when: Seller has 10 or more employees; Your business has 10 or more employees and the product knowingly and intentionally exposes someone in California to this chemical.

• Bisphenol S (BPS) (CAS 80-09-1)

  Listed 2025-12-08 (developmental). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

• N-Methyl-N-Formylhydrazine (CAS 758-17-8)

  Listed 2025-12-08 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

2 rules in New Mexico Per- and Poly-Fluoroalkyl Substances Protection Act (Laws 2025, ch. 102, HB 212), for products sold, from 1 Jan 2027. Conditions differ by rule; see below.

• PFAS as defined in New Mexico (US state)

  Applies when: It contains intentionally added PFAS · The information must be submitted on or before January 1, 2027. The Department may extend the deadline or waive the duty where equivalent information is publicly available.

  Every product in the category · Intentionally added means deliberately added or used during manufacture where its continued presence in the final product or a component is desired or expected.

Applies to products sold on or after 1 Jan 2027. Applies to every product in the category.

Section 4(a) starts January 1, 2027 for every covered product in 23-18.18-3(7). Legislative intent (23-18.18-2) aims at bans by January 1, 2029 unless use is unavoidable; the law text sets no unavoidable-use process. Cookware: durable items used in homes and restaurants to prepare, dispense, or store food, foodstuffs, or beverages (pots, pans, skillets, grills, baking sheets, baking molds, trays, bowls, cooking utensils).

Applies to products sold on or after 1 Jan 2027. Applies when: Contains a battery; It contains or is packaged with a covered battery (a portable battery or, beginning January 1, 2029, a medium format battery, RCW 70A.555.010(1)(a), (5)(a)); a battery that is not intended or designed to be easily removable from the battery-containing product is not a covered battery (70A.555.010(5)(b)(v)), and you are its producer (70A.555.010(14)).

Stated: “Beginning January 1, 2027” (70A.555.020).

Applies to products sold on or after 1 Jan 2027. Applies when: It has a plastic external enclosure, is intended for indoor use and is powered by a standard 120-volt outlet or battery, and the person or entity's worldwide gross sales equal or exceed $1,000,000,000 in 2022 (Group 1).

Stated in WAC 173-337-112(1)(b): the restriction takes effect on 2027-01-01 for persons or entities in Group 1; Group 1 is worldwide gross sales of $1,000,000,000 or more in 2022, Group 2 less. Electronic displays and televisions have their own 2025-01-01 schedule (not stored here).

Applies to products manufactured on or after 31 Jan 2027. Applies when: Your role: Manufacturer or Importer; You manufactured (including imported) a PFAS, or an article containing one, for commercial purposes at any time from January 1, 2011 through December 31, 2022.

Stated in §705.20(a)-(b): “the submission period shall begin January 31, 2027, or 60 days following the date provided in paragraph (c) of this section, whichever is earlier”. Paragraph (c): “EPA intends to publish a document in the Federal Register announcing the submission period date and revising or removing this paragraph (c).” The period had not begun on the date this row was made (2026-10-26); the date is the latest start the text allows.

5 rules in Regulation (EU) 2023/1542 concerning batteries and waste batteries, for products placed on the market, from 18 Feb 2027. Conditions differ by rule; see below.

• Art. 11 removable-replaceable-lmt

  Applies when: Your role: Manufacturer or Importer; Contains a battery; Battery category: LMT battery (e-bike, e-scooter) · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 11 removable-replaceable-portable

  Applies when: Contains a battery; Battery category: Portable battery; Your role: Manufacturer or Importer · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 11 removal-instructions

  Applies when: Contains a battery; Battery category: Portable battery; Your role: Manufacturer or Importer · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 11 software-no-impediment

  Applies when: Contains a battery; Battery category: Portable battery or LMT battery (e-bike, e-scooter); Your role: Manufacturer or Importer · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 11 spare-part-availability

  Applies when: Contains a battery; Battery category: Portable battery or LMT battery (e-bike, e-scooter); Your role: Manufacturer or Importer · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

Applies to products sold on or after 1 Mar 2027. Applies when: Contains a battery; It contains an embedded battery (a portable battery or medium format battery that is contained within a battery-containing product and that is not intended or designed to be easily removable from the product, 38 M.R.S. 1617(1)(M)), and you are the producer participating in a battery stewardship program (1617(2)(B)).

Stated: “Beginning March 1, 2027” (1617(2)(B)); “This paragraph is repealed January 1, 2030.” From then embedded batteries are covered batteries (1617(1)(I)(1)).

2 rules in Commission Regulation (EU) 2023/826 laying down ecodesign requirements for off mode, standby mode and networked standby energy consumption, for products placed on the market, from 9 May 2027. Conditions differ by rule; see below.

• household and office equipment standby

  Max 0.3 W (performance basis) · Applies when: EU ecodesign or energy-label product group: Standby only; Powered from the mains; Rated voltage below 250.01 V; Your role: Manufacturer or Importer · Date computed as two years after the 9 May 2025 application date (Art. 10); the published text states 'two years after the application of this Regulation'.

  Max 7 W (performance basis) · Applies when: Powered from the mains; Rated voltage below 250.01 V; High network availability equipment; Your role: Manufacturer or Importer; EU ecodesign or energy-label product group: Standby only; Connects to the internet or a network · Date computed as two years after 9 May 2025.

Applies to products sold on or after 1 Jul 2027. Applies when: Contains a battery; It contains or is packaged with a covered battery (a portable battery or, beginning January 1, 2029, a medium format battery, RCW 70A.555.010(1)(a), (5)(a)); a battery that is not intended or designed to be easily removable from the battery-containing product is not a covered battery (70A.555.010(5)(b)(v)), and you sell or offer it in or into Washington (a retailer, 70A.555.010(19)).

Stated: “Beginning July 1, 2027, for portable batteries, and July 1, 2029, for medium format batteries” (70A.555.030(1)).

4 rules in Proposition 65 list of chemicals known to the State to cause cancer or reproductive toxicity (27 CCR 27001), OEHHA list, for products sold, from 17 Jul 2027. Applies when: Seller has 10 or more employees; Your business has 10 or more employees and the product knowingly and intentionally exposes someone in California to this chemical.

• Hydrochlorothiazide

  Listed 2026-07-17 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

• Tacrolimus (CAS 104987-11-3)

  Listed 2026-07-17 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

• Voriconazole

  Listed 2026-07-17 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

• Welding Fumes

  Listed 2026-07-17 (cancer). Grace period: "Proposition 65 warning requirements do not apply until 12 months after the chemical has been listed" (Appendix A); listing date plus 12 months.

10 rules in Regulation (EU) 2024/2847 (Cyber Resilience Act) on horizontal cybersecurity requirements for products with digital elements, for products placed on the market, from 11 Dec 2027. Applies when: Your role: Manufacturer.

• Art. 13(1)

  See the published text.

• Art. 13(12)

  See the published text.

• Art. 13(15)

  See the published text.

• Art. 13(16)

  See the published text.

• Art. 13(17)

  See the published text.

• Art. 13(18)

  See the published text.

• Art. 13(19)

  See the published text.

• Art. 13(8)

  See the published text.

• Art. 28(1)

  See the published text.

Applies to products placed on the market on or after 31 Dec 2027. Applies when: Your role: Manufacturer or Importer or Distributor; Contains a battery; Battery category: Portable battery.

Target date 2027-12-31 as stated; Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

8 rules in Proposition 65 clear and reasonable warning regulations (27 CCR Article 6, OEHHA consolidation April 2025), for products manufactured, from 1 Jan 2028. Applies when: Your business has 10 or more employees and the product knowingly and intentionally exposes someone in California to a listed chemical.

• Consumer products that expose a person to a chemical on the Proposition 65 list

  Short-form text required for products manufactured on or after 2028-01-01; available as an option earlier (§25603(b)). Products manufactured and labeled before 2028-01-01 may keep the §25603(c) legacy short form.

Applies to products sold on or after 1 Jan 2028. Applies to every product in the category.

Section 1(a) is stated "(Effective October 1, 2024)". Scope is the union of cookware, carpet or rug, textile furnishing, children's product and upholstered furniture; "textile furnishing" excludes carpets and rugs, which are listed separately. Apparel, cleaning products, cosmetics, dental floss, fabric treatment, menstruation products, ski wax not mapped (no matching product type). Section 1(a) is stated "(Effective October 1, 2024)". "Textile furnishing" excludes carpets and rugs (sub-1(a)(26)), which are item (B)/(3).

Applies to products sold on or after 1 Jan 2028. Applies when: It contains intentionally added PFAS.

Applies to products sold on or after 1 Jan 2028. Applies when: It has a plastic external enclosure, is intended for indoor use and is powered by a standard 120-volt outlet or battery, and the person or entity's worldwide gross sales are less than $1,000,000,000 in 2022 (Group 2).

Stated in WAC 173-337-112(1)(b): the restriction takes effect on 2028-01-01 for persons or entities in Group 2; Group 1 is worldwide gross sales of $1,000,000,000 or more in 2022, Group 2 less. Electronic displays and televisions have their own 2025-01-01 schedule (not stored here).

Max 0.7 ratio (performance basis).

Applies to products manufactured on or after 25 Jul 2028. Applies to every product in the category.