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2025-03-17

NEA newsletter-202503

Latest Progress in Environmental Protection Laws and Regulations, Product Recall Case, and Experts Q&A

California Prop 65 Updates: Vinyl Acetate Listing and BPS Male Reproductive Toxicity Addition
On January 3, 2025, the Office of Environmental Health Hazard Assessment (OEHHA) updated the Proposition 65 list. Vinyl acetate was voted unanimously by the Carcinogen Identification Committee (CIC) to be listed as a carcinogen under California's Proposition 65. Bisphenol S (BPS) was added to the list on December 29,2023, due to its female reproductive toxicity rationale. Now, the Developmental and Reproductive Toxicant Identification Committee (DARTIC) unanimously decided to add the male reproductive toxicity rationale to BPS's listing. Starting from January 3, 2026, companies must provide Californians with clear warnings before knowingly exposing them to the chemical or else face an increasingly frenetic enforcement landscape.

China MIIT released the standard SJ/T 11364-2024
On December 25, 2024, the Ministry of Industry and Information Technology of China issued SJ/T 11364 - 2024 "Labeling requirements for restricted use of hazardous substances in electrical and electronic products" which is China RoHS related standard. DEHP, BBP, DBP, DIBP were added to the list of hazardous substances, and the labeling method was also updated. The new standard will come into effect on April 1, 2025.
On January 14, 2025, the Standard Working Group for Pollution Prevention and Control of Electrical and Electronic Products issued an explanation regarding the coordinated implementation of this standard and No. 1 amendment order of GB/T 26572 - 2011 " Requirements of concentration limits for certain restricted substances in electrical and electronic products ": Enterprises are advised to make full preparations and implement the above two standards simultaneously by January 1, 2026 at the latest.

Singapore regulates long-chain PFCAs and MCCPs
On January 31, 2025, Singapore's Ministry of Sustainability and the Environment (MSE) has added Long-chain perfluorocarboxylic (LC-PFCAs)(chain lengths at least C9 but not exceeding C21); their salts and related compounds, and Medium-chain chlorinated paraffins (MCCPs) (chain lengths at least C14 but not exceeding C17) to its Environmental Protection and Management Act (EPM) 1999 and the Environmental Protection and Management (Amendment) (EMPA) Order. The Directive will come into force on August 1, 2025. LC-PFCAs and MCCPs were included in the list of chemicals to be eliminated (Annex A) of the Stockholm Convention in October 2023. LC - PFCAs are mainly used as plasticizers, flame retardants or lubricants and are widely applied in various fields. MCCPs are commonly used in various industrial applications and can also be used as fire retardants or flame retardants.

Intention to identify 3 substances as SVHC in H1, 2025
Six new substances were proposed to be identified as SVHC for H1, Y2025. But three new substances have been announced to be withdrawn by ECHA. Now only three new substances are still left for H1, Y2025.  Which are Reactive Brown 51, Decamethyltetrasiloxane, 1,1,1,3,5,5,5-heptamethyl-3-[(trimethylsilyl)oxy]trisiloxane. If there is no further withdrawal, the three substances may be identified as SVHC in H1, 2025. The details are shown in the table below.

Substance name EC No/CAS No Status
Reactive Brown 51 466-490-7 / -- Intention
Decamethyltetrasiloxane 205-491-7 / 141-62-8 Intention
1,1,1,3,5,5,5-heptamethyl-3-[(trimethylsilyl)oxy]trisiloxane 241-867-7 / 17928-28-8 Intention
Formaldehyde 200-001-8 / 50-00-0 Withdrawn
Barium chromate 233-660-5 / 10294-40-3 Withdrawn
1,1,1,3,5,5,5-heptamethyltrisiloxane 217-496-1 / 1873-88-7 Withdrawn

The European Union issues Regulation (EU) 2025/40 on packaging and packaging waste
The EU published Regulation (EU) 2025/40 on packaging and packaging waste (the Packaging and Packaging Waste Regulation (PPWR)). It came into force on 11 February 2025 and will apply from 12 August 2026.
The PPWR establishes rules covering the entire life cycle of packaging. It contributes to the efficient functioning of the internal market by harmonizing national measures, while preventing and minimizing the negative impacts of packaging and packaging waste to the environment and human health. Additionally, the PPWR includes waste reduction measures and targets, along with provisions to reduce excessive packaging (including e-commerce packaging), improve recyclability, increase recycled content, phase out hazardous and harmful substances such as per- and polyfluoroalkyl substances (PFAS), and promote reuse.

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