April 7, 2026 | Written by GreenSoft Technology, Inc.

La politique mondiale sur les produits chimiques en marche : quatre périodes de consultation clés sont désormais ouvertes

What these consultations signal, and where industry engagement can shape outcomes

Spring 2026 marks a period of heightened regulatory activity, with multiple public consultations underway across key markets addressing Per‑ and Polyfluoroalkyl Substances (PFAS), Persistent Organic Pollutants (POPs), and Substances of Very High Concern (SVHCs). While each consultation is jurisdiction‑specific, taken together they illustrate both the continued tightening of chemicals regulation and the increasing likelihood of regulatory divergence across markets.

Consultation periods are where regulatory direction is still being shaped, and for electronics manufacturers in particular, understanding what is under discussion and where outcomes may differ between regions is critical.

This post highlights four current consultation periods in the EU, Australia, and the UK, and outlines what they signal for companies managing chemical compliance across complex, multi‑jurisdictional supply chains.

EU: ECHA supports PFAS restrictions with targeted use-specific exemptions

The European Chemicals Agency’s (ECHA) scientific committees continue to advance the proposed EU‑wide PFAS restriction, with the Socio‑Economic Analysis Committee (SEAC) now publishing its draft opinion.

• 60‑day public consultation closes: 25 May 2026.
• Interested parties may submit their comments here

While broad in scope, the proposal reflects a shift toward evaluating potential use-specific exceptions where evidence demonstrates that suitable alternatives are not yet available, and where socio‑economic considerations support a proportionate approach.

This is particularly relevant for highly technical applications, including certain semiconductor, medical, and other industrial uses, where substitution challenges are expected to be a central focus of the consultation.

Australia: National PFAS controls under IChEMS

Australia is progressing expanded controls on a range of PFAS and other industrial chemicals through 14 proposed scheduling decisions under the Industrial Chemicals Environmental Management Standard (IChEMS), along with a proposed variation to an existing standard.

• Consultation closes: Friday, 24 April 2026

• Interested parties may submit their comments online here.

The proposed decisions would assign different chemical groups to IChEMS schedules based on their environmental risk profiles, ranging from lower‑concern substances to chemicals proposed for the most stringent controls. Several PFAS groups are proposed for higher schedules, reflecting concerns about persistence, mobility, and environmental harm.

Interested parties may submit their comments online here.

UK POPs Regulation: Partial alignment with EU POPs, but scope and thresholds still under consultation

The UK Department for Environment, Food and Rural Affairs (Defra) is consulting on amendments to the UK Persistent Organic Pollutants (POPs) Regulation, proposing to add five substances to Annex I:

• Dechlorane Plus
• UV‑328
• Long‑chain perfluorocarboxylic acids (LC‑PFCAs)
• Medium‑chain chlorinated paraffins (MCCPs)
• Chlorpyrifos

Public consultation closes 13 May 2026. Interested parties may submit their comments here.

These substances are already listed, or in the process of being listed, under the EU POPs Regulation, reflecting decisions taken under the Stockholm Convention. The UK proposals are therefore aligned in principle with EU POPs controls, but Defra is consulting on how those controls should be implemented in Great Britain.

In particular, the consultation seeks evidence on:

• Unintentional trace contaminant (UTC) limit values
• Transitional arrangements and timelines
• The treatment of certain articles and legacy materials

As a result, while the list of substances is broadly aligned with the EU, implementation details may differ, and companies operating across both Great Britain and EU markets should monitor outcomes closely for potential compliance divergence.

UK SVHCs: UK REACH begins updating the Candidate List to match EU REACH

The UK Health and Safety Executive (HSE) is consulting on the proposed addition of 15 Substances of Very High Concern (SVHCs) to the UK REACH Candidate List, marking the first update to the list since the UK left the EU.

• Consultation closes: 20 April 2026
• Comments are submitted via HSE’s Citizen Space platform, through the individual substance consultation pages available here.

All 15 proposed substances are already listed on the EU REACH SVHC Candidate List. While the substances and hazard rationales align with the EU REACH SVHC Candidate List, downstream requirements are not fully identical: both EU and UK REACH apply the 0.1% w/w per‑article communication threshold, but obligations such as SCIP notifications apply only in the EU, and any future restrictions, authorization requirements, or use‑specific conditions would be determined separately under UK REACH.

This consultation reflects the UK’s stated policy of using the EU REACH SVHC Candidate List as a baseline reference point while operating an independent SVHC identification process under UK REACH, following a period in which the UK list remained unchanged while the EU list expanded.

GreenSoft has previously published a detailed analysis of the UK government’s approach to SVHC alignment and its implications for compliance, available here.

What this means for electronics manufacturers

For electronics manufacturers, these consultations collectively point to increasing scrutiny of materials used in components, assemblies, and finished products, particularly where substances are persistent, difficult to substitute, or present in legacy articles.

Several themes are especially relevant to the electronics sector:

• Expanded PFAS and POPs controls may affect coatings, adhesives, cables, connectors, housings, and thermal management materials.
• Unintentional trace contaminant (UTC) limits under POPs regimes heighten the importance of understanding impurities and recycled content, not just intentionally added substances.
• SVHC list updates continue to increase downstream communication and disclosure obligations, even where no immediate ban applies.
• Jurisdictional divergence, particularly between the EU and Great Britain, increases the risk that a single product configuration may not meet all market requirements without careful compliance planning.

For companies with complex global supply chains, these developments reinforce the need for accurate, substance‑level data across materials, parts, and articles, as well as the ability to assess regulatory exposure across multiple regions at once.

Why industry input during consultation periods matters

Consultation periods are the point in the regulatory process where details that matter in practice are still negotiable. For chemical regulations in particular, this is where proposed requirements are tested against real‑world use, feasibility, and implementation challenges.

Industry input can directly affect:

• Scope definitions, including how substances are defined and grouped
• Thresholds and limit values, particularly for unintentional trace contaminants
• Timelines and transition periods, which are critical for redesign and qualification cycles
• Specific-use exemptions, especially for applications where substitution is not yet technically feasible

Regulators frequently rely on stakeholder submissions to understand real‑world use conditions, analytical limitations, and supply‑chain realities that are not visible from hazard or dossier data alone. Where such information is not provided, rules tend to default to more conservative assumptions.

Input provided at this stage can play a meaningful role in shaping how proposed requirements are ultimately implemented.

Next steps and how GreenSoft helps

As these consultation processes progress, requirements will continue to evolve. Staying informed and prepared is essential.

GreenSoft supports electronics manufacturers by:

• Monitoring regulatory developments across PFAS, POPs, SVHCs, and other regulations
• Keeping customers informed as consultations close and final measures are adopted
• Helping translate regulatory text into product‑level compliance impacts
• Supporting data collection, analysis, and reporting needed to demonstrate compliance across regions

We will continue to provide updates on our blog as these proposals move toward finalization and new obligations take effect, helping companies anticipate change rather than react to it.

If you would like to discuss how these consultations may affect your products or supply chain, GreenSoft’s regulatory and data services teams are available to support you. Contact us today to learn more.