Full Material Declaration (FMD)
August 20, 2025 | Written by GreenSoft Technology, Inc.
Staying Ahead of the Curve:
A Look at Regulatory Updates over the Past 5 Years
Frequent Substance List Updates Are Creating a New Compliance Burden
Environmental regulations are constantly evolving. New substances are added to restricted lists, exemptions expire or change, and entirely new regulations and reporting obligations emerge, sometimes with short notice. For manufacturers and suppliers, this dynamic landscape can pose a significant challenge: how do you ensure your product data remains accurate and up to date as the rules change?
Below, we take a look at just how many updates have been made to key environmental regulations in the past five years alone, and what that means for companies managing compliance. We'll also highlight the role of Full Material Declaration (FMD) data as a powerful tool for reducing the burden of repeated supplier outreach and ensuring long-term compliance.
How Frequently Are Regulations Updating?
Since 2020, several key global environmental regulations have issued regular updates to their restricted substance lists, exemptions, and reporting requirements. Below are some of the regulatory updates and new regulations that have published over the past five years, focusing on the most relevant updates for electronics producers.
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Regulation / Substance List |
Updates Made Since 2020 |
Upcoming Updates |
Notes |
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EU RoHS Exemptions list |
Dozens of updates |
Additional updates to key Annex III exemptions, including 7(a), 7(c)-I, 7(c)-II, 6(a), 6(b), and 6(c) are expected in 2025. |
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EU REACH SVHC list |
49 new substances added |
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New substances are added to the EU REACH SVHC List every 6 months or twice per year, with the exception of 2024 which saw 3 updates to the list.
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EU REACH Annex XVII |
10+ updates |
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EU REACH Annex XIV |
2+ updates |
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Persistent Organic Pollutants (EU POPs) Regulation |
10+ updates
At least 2 updates have been made to the Stockholm Convention that affect the EU POPs Regulation. |
10 new substances are expected to be added in September/October 2025. |
31 substances/substance groups are currently regulated under EU POPs. |
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PFAS Reference Lists |
At least 5 updates have been made to the Organisation for Economic Co-operation and Development (OECD) and the U.S. Environmental Protection Agency (EPA) PFAS reference lists |
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New Regulations Added Since 2020 |
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New Regulation / Requirement |
Details |
Updates Made Since First Published |
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EU Battery Regulation |
Changed from a Directive to a Regulation in July 2023 with additional substance restrictions and labeling requirements. However, the Due Diligence requirement has been delayed to 2027. |
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Packaging and Packaging Waste Regulation (PPWR) |
Changed from a Directive to a Regulation in December 2024 with stricter requirements on recyclability, reusability, and the restriction of hazardous substances, including PFAS. |
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Maine’s PFAS Regulation |
Maine’s PFAS Regulation was published in December 2024 regulating intentionally added PFAS sold in the state. |
The reporting deadline has been delayed twice and notification requirements have been revised. |
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Minnesota’s PFAS Regulation |
Minnesota’s PFAS Regulation was signed into law in May 2023 and regulates the sale of intentionally added PFAS in the state. |
The reporting deadline has been delayed since the rule was first published. |
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New Mexico’s PFAS Regulation |
New Mexico’s PFAS Regulation was passed in April 2025 regulating intentionally added PFAS sold in the state.
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Canadian Environmental Protection Act (CEPA) 71(1)(b) |
From July 2024 – January 2025, Canadian Environmental Protection Act (CEPA) 71(1)(b) required companies to report on their import, production, and usage of 312 in-scope PFAS during the calendar year of 2023.
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Australian PFAS Ban |
In July 2025, Australia officially banned three specific PFAS chemicals–PFOS, PFOA, and PFHxS (including salts, isomers, and precursors)–under Industrial Chemicals Environmental Management Standard (IChEMS).
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U.S. TSCA Rule 8(a)(7) |
Published in October 2023, U.S. TSCA Rule 8(a)(7) mandates manufacturers to report and maintain records for specific PFAS (currently 12,161 substances). |
The start of the reporting period has been delayed two times since the rule was published. |
What These Updates Mean for You
Regulatory updates like these may require:
- New or updated compliance declarations
- Re-assessment of parts and materials
- Recollection of documentation from suppliers
- Changes to internal systems and compliance processes
For companies managing compliance in-house, staying ahead of these updates demands constant monitoring and frequent supplier engagement. Even small changes—like an addition to the EU REACH SVHC list or Prop 65 list—can trigger significant internal workload and potential risk exposure.
Full Material Declaration (FMD) Data is the Key to Long-Term Compliance
One of the most effective ways to stay proactive in the face of regulatory changes is by collecting Full Material Declaration (FMD) data on your parts and components.
FMD data provides complete material composition information for a part or component. With this level of transparency, you don’t need to go back to the supplier each time a regulation changes. You can simply re-analyze your existing FMD data against the latest substance lists.
This means:
- No repeated outreach to suppliers
- No waiting for updated declarations
- Faster reaction time to regulatory changes
- Reduced risk of non-compliance
How GreenSoft Helps You Stay Compliant
From twice yearly EU REACH SVHC list updates to the growing wave of PFAS legislation, staying compliant requires ongoing attention and a flexible strategy.
GreenSoft continuously monitors global environmental regulations and keeps our compliance databases up to date so you don’t have to. Our expert team handles supplier outreach, data collection, validation, and ongoing monitoring for your parts list, giving you peace of mind and a proactive compliance strategy.
And by prioritizing collecting FMD data, we help future-proof your compliance and minimize the disruptions caused by frequent regulatory updates.
Learn about how our Data Collection Services and GreenData Manager compliance software can simplify your compliance efforts. Contact us to get started with a personalized demo.
