Global Material Compliance Playbook 2026: Key Rules

Global material compliance is changing from a periodic product-checking exercise into a continuous data-management responsibility.

Manufacturers selling internationally must now deal with overlapping requirements for restricted substances, substances of very high concern, PFAS, persistent organic pollutants, packaging materials, batteries, waste obligations, supplier declarations and increasingly detailed product information.

At the same time, the rules are not becoming globally uniform.

A product that complies with EU RoHS does not automatically satisfy every chemical or material requirement in the United States, China, India, Saudi Arabia, the United Kingdom or other target markets. Requirements can differ by jurisdiction, product category, material, concentration threshold, company role and date of market placement.

That makes a simple country checklist insufficient.

The more scalable approach is to connect four elements:

Product → Market → Regulatory Requirement → Compliance Evidence

This 2026 Global Material Compliance Playbook explains how businesses can build that connection and highlights several of the regulatory developments that should be on compliance teams' agendas now.

Several developments have made 2026 particularly important for companies managing material and substance compliance.

The EU REACH Candidate List reached 253 entries in February 2026 after ECHA added n-hexane and 4,4'-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol and its salts. Inclusion can immediately create communication and other obligations for affected companies.

EU PFAS regulation is also developing on several fronts. The proposed broad REACH PFAS restriction has moved through scientific evaluation, with ECHA's Risk Assessment Committee adopting its opinion in March 2026 and the Socio-Economic Analysis Committee progressing its opinion. The proposal remains a regulatory process rather than a blanket EU PFAS prohibition already in force.

At the same time, a separate PFAS requirement has already entered application: the EU Packaging and Packaging Waste Regulation, or PPWR, has applied since 12 August 2026, including specific PFAS concentration limits for food-contact packaging.

RoHS is changing as well. Several important lead exemptions were revised in 2025, resulting in transition and expiry dates during late 2026 and 2027. Companies that previously relied on broad exemptions need to confirm whether their application continues to fall within a valid exemption rather than assuming previous declarations remain sufficient.

Outside Europe, U.S. PFAS requirements continue to develop at federal and state level, while China is preparing for a new mandatory hazardous-substance standard for electrical and electronic products.

The result is a material-compliance landscape driven not by one global rulebook, but by increasingly interconnected national and regional requirements.

Material compliance in 2026 should extend beyond basic RoHS testing.

A mature program should be able to evaluate:

The objective should not be to collect as many documents as possible.

The objective is to determine whether each regulated product can be supported by current, relevant and traceable evidence for every market where it is sold.

EU REACH Candidate List Reaches 253 Entries

As of September 2026, ECHA's Candidate List contains 253 entries. Two entries were added on 4 February 2026.

The number matters because Candidate List additions can create immediate obligations.

For articles containing a Candidate List substance above 0.1% weight by weight, suppliers can have communication obligations under REACH Article 33. EU and EEA suppliers placing affected articles on the market may also have SCIP notification obligations under the Waste Framework Directive.

For manufacturers, this means a supplier declaration that was valid when originally collected can become incomplete after the Candidate List changes.

A practical process is therefore to connect supplier declarations with the regulatory-list version used during evaluation. When the list changes, potentially affected products should be identified automatically for reassessment.

SCIP Requires Product-Level Substance Traceability

SCIP should not be managed as an isolated submission activity.

ECHA requires information for affected articles including identification of the article, relevant Candidate List substance, concentration range, location in the article and information supporting safe use and waste management.

That information often originates deep within the supply chain.

Manufacturers should therefore be able to trace:

Finished Product → Assembly → Component → Material → Substance

Without that hierarchy, updating SCIP information after a component, material or supplier change can become a highly manual exercise.

EU RoHS Exemptions Require Renewed Attention

EU RoHS continues to restrict ten substances in electrical and electronic equipment, including lead, mercury, cadmium, hexavalent chromium, PBB, PBDE and four phthalates.

However, simply checking the restricted-substance list is no longer enough.

Several lead exemptions have been restructured.

For example, Delegated Directive (EU) 2025/2364 sets new dates for exemptions relating to lead in steel, aluminium and copper. The previous 6(a) entry expires on 11 December 2026, while several replacement or narrower entries run into 2027. Some 6(b) applications also have different dates depending on the equipment category.

High-melting-temperature solder exemption 7(a) has also been restructured, with different applications extending through 30 June or 31 December 2027.

For businesses, the important question is not simply:

"Does our product use a RoHS exemption?"

It is:

"Which exact exemption, for which application, for which equipment category, and until what date?"

Exemption identifiers should therefore be linked directly to parts and materials in the BOM rather than stored only inside a general supplier declaration.

PFAS illustrates why global substance management can no longer rely on one restricted-substance list.

EU-Wide PFAS Restriction Proposal

The proposed universal PFAS restriction under REACH continues to move through ECHA's scientific assessment process. In March 2026, RAC adopted its opinion, while SEAC progressed its socioeconomic assessment and consultation. ECHA has indicated support for restriction accompanied by targeted derogations.

Businesses should distinguish this developing proposal from requirements that are already legally applicable.

A proposal should trigger readiness activities, not be recorded as though the final restriction has already entered into force.

That means identifying PFAS uses, suppliers, functions, concentrations where available, potential alternatives and business-critical applications before final requirements arrive.

PPWR PFAS Requirements Are Already Applicable

The EU PPWR is different.

Since 12 August 2026, food-contact packaging may not be placed on the EU market when PFAS are present at or above specified concentration limits. The regulation includes limits of 25 ppb for any PFAS measured by targeted analysis and 250 ppb for the sum of PFAS measured using targeted analysis, subject to the Regulation's detailed conditions.

The European Commission has also issued 2026 implementation guidance dealing with testing and market-placement questions.

For companies selling packaged products, this creates an important operational lesson:

Packaging material data should be incorporated into the same compliance system as product material data.

A compliant finished product can still face market-access issues if regulated packaging materials are not evaluated.

The EU Batteries Regulation demonstrates how material compliance is increasingly connected to digital product information.

From 18 February 2027, each LMT battery, industrial battery above 2 kWh and electric-vehicle battery within scope must have an electronic battery passport.

The Regulation also requires QR-code-based access to specified information from that date.

Meanwhile, the application of battery supply-chain due-diligence obligations was postponed to 18 August 2027 by Regulation (EU) 2025/1561.

Companies affected by these rules should avoid building separate datasets for material compliance, supplier due diligence and battery passports.

The same underlying data—materials, substances, suppliers, product identifiers and supporting evidence—should be structured so that it can serve multiple regulatory outputs.

Companies operating across Europe should maintain separate regulatory applicability for the European Union and the United Kingdom.

Great Britain continues to operate its own RoHS Regulations, while Northern Ireland can be subject to different arrangements. UK REACH also maintains its own Candidate List process.

This means an EU regulatory update should not automatically be copied into a UK product compliance decision.

Regulatory teams should maintain separate jurisdiction records even where requirements currently appear similar.

That approach becomes increasingly important over time as exemption decisions, Candidate List entries and regulatory amendments diverge.

The United States is one of the clearest examples of why a country-level "PFAS compliant" statement is insufficient.

Federal TSCA PFAS Reporting

EPA's TSCA Section 8(a)(7) PFAS reporting rule covers historical PFAS manufacturing and importing activity, including certain imported products under the existing rule structure.

However, its implementation schedule and scope have been under revision.

In April 2026, EPA finalized another timing change. Under that action, the submission period will begin on 31 January 2027 or 60 days after the effective date of EPA's forthcoming substantive revision to the rule, whichever occurs earlier.

EPA has separately proposed changes to the rule's scope, including possible exemptions for certain imported articles, low-concentration PFAS, impurities and other categories. Those proposed scope changes should not be treated as final until the substantive rulemaking is completed.

For companies importing into the United States, monitoring the final scope is therefore essential.

Minnesota PFAS Reporting

Minnesota's requirements have progressed much further.

Manufacturers of covered products containing intentionally added PFAS had an initial reporting deadline of 15 September 2026. Manufacturers receiving approved extensions have a later 14 December 2026 deadline, while subsequent reports may be required annually on 1 February.

Minnesota is also moving toward broader restrictions on intentionally added PFAS, with a general prohibition planned for 2032 unless the use qualifies as currently unavoidable.

Maine PFAS Restrictions

Maine eliminated its earlier general reporting model and replaced it with a framework built around product-category restrictions and Currently Unavoidable Use determinations.

Restrictions for several product categories—including cookware, cleaning products, cosmetics, juvenile products, textiles, dental floss, ski wax and upholstered furniture—took effect on 1 January 2026, subject to statutory exemptions and other provisions.

A much broader prohibition is scheduled for 1 January 2032, again subject to exemptions and approved unavoidable uses.

Washington PFAS Requirements

Washington State also adopted new PFAS requirements.

Reporting requirements for specified product categories took effect on 1 January 2026, with first notifications due 31 January 2027. Restrictions covering intentionally added PFAS in apparel and accessories, automotive washes and cleaning products are scheduled to begin 1 January 2027.

The practical conclusion is clear:

A supplier statement saying simply "PFAS-free" or "compliant with U.S. PFAS regulations" may not provide enough information to support multiple state requirements.

Companies increasingly need product-category, substance, function and jurisdiction-specific information.

Canada published its final State of PFAS Report in March 2025.

The report concluded that the class of PFAS, excluding fluoropolymers as defined in the report, meets criteria under the Canadian Environmental Protection Act. Canada subsequently proposed adding the class, excluding those fluoropolymers, to Part 2 of Schedule 1 to CEPA and began developing a phased risk-management approach.

For companies, this is a strong reason to begin identifying PFAS uses in Canadian product portfolios even where a particular final product restriction has not yet entered into force.

Regulatory monitoring should clearly distinguish:

Assessment → Proposal → Consultation → Final Requirement → Effective Date

Treating those stages separately prevents businesses from either reacting too late or treating proposals as existing law.

China is preparing for a significant change in hazardous-substance compliance for electrical and electronic products.

The new GB 26572-2025, "Requirements for restricted use of hazardous substances in electrical and electronic products," was published in 2025 and becomes mandatory on 1 August 2027. It will replace GB/T 26572-2011.

China's Ministry of Industry and Information Technology states that the new mandatory standard controls ten hazardous substances, including four heavy metals, PBB, PBDE and four phthalates.

A transition is already under way. Chinese authorities have provided conformity-assessment transition arrangements between the existing standard and GB 26572-2025.

Manufacturers selling electronics into China should therefore be reviewing existing declarations, testing strategies and conformity documentation before the 2027 mandatory date.

Waiting until August 2027 would leave little time to correct supplier-data gaps.

India's E-Waste (Management) Rules, 2022 have applied since 1 April 2023 and combine electrical and electronic waste obligations with restrictions on hazardous substances for covered equipment.

The Central Pollution Control Board explains that covered electrical and electronic equipment must comply with concentration limits for lead, mercury, hexavalent chromium, PBB and PBDE of 0.1% by weight in homogeneous material, while cadmium is limited to 0.01%.

For international manufacturers, India provides another example of why substance compliance and EPR should not be managed as completely separate workstreams.

Product scope, producer status, regulatory registrations and material information can affect several compliance processes at once.

Saudi Arabia maintains its own Technical Regulation for Restriction of Hazardous Substances in Electrical and Electronic Equipment.

For covered products, the regulation includes hazardous-substance requirements together with conformity-assessment and technical-file obligations.

This highlights an important difference between global markets.

Material composition is only one part of market access.

A business may also need the correct conformity procedure, product documentation, supplier evidence, registration and supporting technical records before the product can legally enter the market.

Because several requirements remain subject to amendments, exemptions or product-specific conditions, companies should always validate applicability to their own product, role and market before relying on a deadline.

1. Define the Product and Target Markets

Start with exactly what is being sold and where.

A regulatory assessment should identify the product category, intended use, components, packaging, batteries, accessories and target jurisdictions.

Do not start by asking whether a product is "globally compliant."

Global compliance is the combined result of individual market assessments.

2. Build a Structured Multi-Level BOM

Create visibility from finished product to component, material and substance.

Where possible, maintain:

Product ID → Assembly → Component → Material → Substance → Supplier

This structure makes it possible to identify every affected item when a substance restriction, Candidate List entry or exemption changes.

3. Build a Regulatory Applicability Matrix

Link each product and market to the relevant regulatory requirement.

The matrix should distinguish between:

• applicable legislation;
• applicable substance list;
• concentration threshold;
• relevant exemption;
• supplier-information requirement;
• reporting obligation;
• required technical evidence;
• effective date;
• next regulatory review date.

This prevents one generic compliance declaration from being reused incorrectly across different jurisdictions.

4. Create a Controlled Restricted Substances List

An internal Restricted Substances List should consolidate the requirements that actually apply to the company's products and markets.

It may include substances from REACH, RoHS, POPs, PFAS laws, TSCA, customer specifications and industry-specific requirements.

The RSL should be version-controlled.

Every supplier declaration should be traceable to the RSL or regulatory version against which it was completed.

5. Collect Supplier Data According to Risk

Not every component needs the same level of evidence.

Higher-risk materials may require detailed substance data or laboratory testing, while lower-risk components may be managed through structured supplier declarations supported by appropriate documentation.

Useful evidence can include:

• Full Material Declarations;
• IPC-1752A or IPC-1752B declarations;
• IEC 62474 declarations;
• material and substance composition;
• certificates of compliance;
• analytical test reports;
• exemption declarations;
• PFAS declarations;
• regulatory questionnaires;
• supporting technical records.

ComplyMarket's published material-compliance approach also references IEC 63000, IEC 62474 and IPC-1752B for structured supplier and material-compliance processes.

6. Validate Evidence Instead of Simply Collecting It

A PDF stored in a folder does not automatically demonstrate compliance.

Review:

Scope: Does the evidence identify the correct product or part?

Regulation: Which regulation or substance list does it cover?

Version: Is the declaration based on the current regulatory list?

Threshold: Does it provide sufficient information to evaluate the relevant concentration limit?

Exemptions: Are claimed exemptions still valid?

Supplier: Can the evidence be linked to the current supplier and manufacturing source?

Date: Has the product, material or regulation changed since the evidence was issued?

7. Apply Risk-Based Testing

Laboratory testing should supplement supplier information where the compliance risk justifies it.

Testing can be prioritized using factors such as:

• material type;
• known high-risk substances;
• supplier reliability;
• geographic sourcing risk;
• previous non-conformities;
• declaration quality;
• regulatory importance;
• exemption dependency.

This approach focuses testing budgets on areas where analytical verification provides the greatest value.

8. Monitor Changes and Reassess Automatically

Compliance does not end when a product is launched.

A regulatory change can invalidate an earlier conclusion even when the physical product has not changed.

A controlled system should therefore identify products affected when:

• a new SVHC is added;
• a restriction is amended;
• an exemption expires;
• a PFAS requirement enters into force;
• a supplier changes;
• a component is replaced;
• a declaration expires;
• a new market is added.

That is the difference between a compliance archive and a compliance management system.

Assuming EU Compliance Means Global Compliance

EU regulations are influential, but other jurisdictions maintain their own scope, substance lists, conformity processes and reporting obligations.

Use EU compliance as one jurisdictional assessment, not as a universal legal conclusion.

Asking Suppliers Only Whether a Product Is "Compliant"

A yes-or-no answer provides little information when regulations change.

Ask suppliers for the substance data, affected materials, exemptions and supporting evidence behind the conclusion.

Treating an SDS as Complete Product Composition Data

Safety Data Sheets serve a specific chemical hazard communication purpose and do not necessarily provide complete substance information for finished articles.

Use the evidence type appropriate to the compliance question.

Treating Proposed Rules as Final Law

PFAS regulation demonstrates how rapidly proposals, consultations, exemptions and implementation dates can change.

Track regulatory status explicitly.

Separating Product, Supplier and Compliance Data

When BOM information is stored in one system, supplier declarations in email, legislation in spreadsheets and evidence in shared folders, every regulatory update becomes a manual reconciliation exercise.

Connected data enables affected products to be identified much faster.

A useful management dashboard should answer questions such as:

These are operational questions.

A compliance system should make them answerable without rebuilding the analysis every time someone asks.

One of the most important developments for manufacturers is the convergence of material compliance, sustainability information and digital product data.

The EU Battery Passport is already demonstrating this direction.

Future compliance processes increasingly depend on structured information about materials, substances, suppliers, recycled content, product identifiers and lifecycle characteristics.

Companies that continue to store this information only in isolated declarations may therefore face a second problem later: even if the information exists, it may not be structured well enough to reuse for digital reporting.

The best preparation is to build a reusable product-data foundation now.

Managing global material compliance requires more than maintaining a database of restricted substances.

Companies need to connect regulatory requirements with the products, materials, suppliers and evidence affected by those requirements.

ComplyMarket provides a connected compliance environment designed to support that process.

The platform can bring together product structures, multi-level BOMs, components, materials, substances, supplier information and compliance documents within one structured system. Its product-management capabilities support traceability from materials and components through to finished products and allow compliance evidence to be linked directly to relevant items.

Regulatory requirements can then be connected to products and jurisdictions so teams can evaluate compliance and marketability against the markets in which products are sold.

Supplier workflows support the collection and management of declarations and supporting evidence, while compliance status and warning functionality can help teams identify missing information or products that require reassessment after a change.

For material-compliance programs specifically, ComplyMarket supports workflows around areas such as REACH, RoHS, SCIP, PFAS and other restricted-substance requirements, together with supplier data collection and evidence management.

The objective is to establish one connected compliance process:

Regulation → Requirement → Product → BOM → Material → Substance → Supplier → Evidence → Compliance Decision

For manufacturers, importers, distributors and international product businesses, that structure can make global compliance more scalable, auditable and responsive to regulatory change.