Global Regulatory Update for October 2026

“EU and UK REACH Developments and Compliance Priorities,” November 3, 2026, 11:00 a.m. – 12:00 p.m. (EST), Via Webinar

The Acta Group (Acta^®) is pleased to present “EU and UK REACH Developments and Compliance Priorities,” a complimentary webinar examining recent developments under European Union (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and United Kingdom (UK) REACH and their practical implications for companies operating in European markets. Christine M. Palermo, Ph.D., DABT, Director of Regulatory Sciences, Acta; Emma Louise Jackson, Manager, UK REACH, Acta; Max L. Moseley, MSc, Regulatory Scientist, Acta; and Lynn L. Bergeson, President, Acta, will present. Register now.

On-Demand Webinar: “Plastics and Policy: Microplastics, EPR, and Other Emerging Trends”

Acta affiliate Bergeson & Campbell, P.C. (B&C^®) is pleased to share an on-demand recording of “Plastics and Policy: Microplastics, EPR, and Other Emerging Trends,” a complimentary webinar presented by Lynn L. Bergeson, Managing Partner, B&C; Lindsay A. Holden, Ph.D., DABT, Senior Toxicologist/Regulatory Scientist, B&C, and B&C Associates L. Claire Hansen and Catherina D. Narigon. During this webinar, speakers covered how emerging microplastics, extended producer responsibility (EPR), and recycling laws, such as California’s “Truth in Recycling” law and the EU Packaging and Packaging Waste Regulation (PPWR), affect plastic products and packaging stakeholders, how recent initiatives and legal challenges may affect the commercial landscape, and what stakeholders can do now to minimize legal, regulatory, and commercial risk. Speakers also provided a comparison of U.S. plastics and microplastics regulation with the EU regulatory framework. Watch now.

CANADA

Canada’s Proposed Food Packaging Framework Would Require Notification Of FCMs

Anticipating an increase in the use of recycled plastics, Health Canada held public consultation on a high-level overview of a proposed food packaging framework. Under Canada’s Food and Drug Regulations (FDR), Health Canada currently conducts a premarket assessment of a food contact material (FCM) only when a request is voluntarily submitted. According to Health Canada’s consultation document, this “may limit Health Canada’s ability to proactively identify and respond to emerging chemical risks associated with food packaging.” Under the proposed food packaging framework outlined in the consultation document, there would be a mandatory notification requirement for FCMs.

Comments on the proposed framework were due October 9, 2026. Health Canada will use the feedback provided to develop further recommendations on options for a mandatory food packaging framework. Health Canada expects to hold a second public consultation between November 2026 and January 2027. According to Health Canada, pending the outcomes of these consultations, it will internally consider recommendations for a mandatory food packaging framework by Spring 2027. Depending on the option(s) chosen, regulatory development may begin thereafter, in accordance with the Cabinet Directive on Regulation. Health Canada notes that there will be further opportunities for consultation and program refinement as part of this process. More information is available in our August 24, 2026, memorandum.

Canada Issues Section 71 Notices To Obtain Information On Certain Substances, Will Hold First Information Session In October 2026

On August 29, 2026, Canada published two notices under Section 71(1)(b) of the Canadian Environmental Protection Act, 1999 (CEPA) to collect information for the purpose of prioritization, risk assessment, and risk management. Canada is gathering information from Canadian manufacturers, importers, and users on the commercial status, facility information (such as releases), and uses of these substances in Canada. The notice for Phase 1 applies to 184 substances identified as a priority for information gathering under the Chemicals Management Plan (CMP). Responses for Phase 1 substances are due March 3, 2027. The notice for Phase 2 applies to 16 substances identified as a priority for information gathering under the CMP. The reporting period for Phase 2 substances will begin March 4, 2027, and responses are due September 8, 2027. Canada will hold a series of information sessions to support stakeholders’ understanding of the notices. The information sessions will be offered in both English and French on October 14, 2026, December 2, 2026, and March 17, 2027. To register, stakeholders should complete the Section 71 CMP 2026 — Information session interest form. Canada will send an Outlook invitation to the meeting a few days before the information session. Responding to the notices is mandatory. More information is available in our October 8, 2026, memorandum.

Canada Begins Public Consultation On Proposed CMR Criteria

Canada published a notice on October 3, 2026, announcing that the Minister of the Environment and the Minister of Health are initiating the development of proposed regulations under CEPA Section 67 that would set out the criteria for carcinogenicity, mutagenicity, and reproductive toxicity (CMR) of substances for the purpose of CEPA Section 77(3). The consultation document states that for the purpose of the proposed regulations, Canada proposes to align its definitions of CMR with the United Nations’ (UN) Globally Harmonized System of Classification and Labelling of Chemicals (GHS) criteria and considerations. According to the consultation document, this approach “will build on an existing body of research and can be used to inform future updates to the regulations based on the latest information and scientific knowledge.” When developing these regulations, Canada proposes to incorporate the criteria either by reference to the Hazardous Products Regulations (HPR) or the most recent revision of the GHS purple book. To assist with the development of the proposed regulations, Canada has identified the following questions and areas of interest for which input is being sought:

• What are your views on the proposed criteria for CMR?

• What other criteria or considerations, if any, should be included in the proposed criteria for CMR?

According to the consultation document, Canada plans to publish proposed regulations for public comment by 2027. Comments on the consultation document are due December 2, 2026.

EU

The EU Ecolabel Is A Practical Tool For Linking Circularity Objectives To Everyday Market Choices

Established in 1992, the EU Ecolabel is a world-renowned voluntary label that promotes environmental excellence through standardized processes and science-based criteria. As the European Commission (EC) transitions to a circular economy — moving away from the traditional linear model of “take, make, use, dispose” toward one in which products and materials remain in circulation and waste is minimized — the EU Ecolabel considers the environmental impacts across a product’s entire lifecycle. The EU Ecolabel is awarded to high-quality, best-in-class goods and services placed on the EU market based on their environmental performance. According to statistics from the EC, the most popular Ecolabel product categories by number of certified products include paints and varnishes, paper products, cleaning products, and clothing and textiles. Notably, an estimated 61 percent of companies with EU Ecolabel-awarded products are registered as small and medium-sized enterprises (SME). Obtaining the EU Ecolabel requires meeting additional environmental performance criteria that extend beyond the minimum requirements established under mandatory legislation, including the EU’s REACH Regulation. Applications are assessed by independent third-party Competent Bodies in accordance with ISO 14024 principles and procedures. More information is available in our July 30, 2026, blog item.

EU Packaging And Packaging Waste Regulation Begins To Apply August 12, 2026

On August 12, 2026, the EU PPWR officially replaced the EU’s longstanding Packaging and Packaging Waste Directive (PPWD). Where the PPWD provided EU member states with both regulatory and implementation flexibility, meaning that each member state could take a different approach to implementation, the PPWR brings harmonized standards across the EU. This change seeks to bring cohesion across member states to encourage a circular economy and a consistent regulatory scheme. The PPWR entered into force on February 11, 2025, but provided an 18-month period before its general application. The PPWR is designed to be implemented in phases, meaning that different requirements will become applicable over time. August 12, 2026, does not represent implementation of the PPWR in its entirety. It does, however, mark an important compliance date for several of the PPWR’s initial requirements. Manufacturers, importers, and other entities bringing or distributing packaging and packaged products into the EU should ensure familiarity with the PPWR’s requirements. More information is available in our August 12, 2026, blog item.

EU CLP Update: Aligning With Recent UN GHS Revisions

The EC has proposed an update to the EU’s Classification, Labelling and Packaging (CLP) Regulation to align better with recent revisions to the GHS. The notification, published on August 17 , 2026, announces integration of GHS revisions 8 to 11 into the CLP Regulation, with the following changes:

• New classification criteria or procedures, hazard communication elements, decision logics, and guidance for chemicals under pressure, as well as amendments to address better their explosion hazard when they are not in their transport configuration;

• Revised and further rationalized precautionary statements to inter alia improve users’ comprehension while also taking into account usability for labeling practitioners;

• The use of non-animal testing methods for the classification of health hazards relating to certain hazard classes;

• The introduction of new provisions for the use of in vitro/ex vivo data and non-test methods of assessing skin corrosion and skin irritation;

• The alignment of the classification strategy, guidance, and tools on metals and metal compounds with the provisions for long-term aquatic classification toxicity;

• Amendment of the classification criteria and provisions for skin-sensitizing mixtures, thus concluding the work that was initiated in the tenth revised edition with the revision of the classification criteria for substances with skin-sensitizing properties; and

• Amendments to the classification criteria for substances and mixtures that are hazardous to the atmospheric system, as well as further rationalization and streamlining of precautionary statements.

The EC has proposed adoption of these amendments in the fourth quarter of 2026. Stakeholders can provide comments regarding the notification up until October 16, 2026, through contact with the relevant team at grow-eu-tbt@ec.europa.eu. More information is available in our August 27, 2026, blog item.

Is The Mixture Assessment Factor Still On The REACH Agenda?

Following the April 27, 2026, European Parliament’s (EP) Environmental Committee announcement that the EC would not proceed with a legislative proposal for a comprehensive revision of EU REACH, major reforms — such as the registration of polymers — appear to be off the table. Technical amendments to the REACH Annexes through comitology remain possible, however, although it is not yet clear which of the proposed initiatives previously identified by the EC will be taken forward. One initiative that may still be worth watching is the Mixture Assessment Factor (MAF).

On August 19, 2026, the EC’s Directorate-General for Environment (DG ENV) highlighted academic research supporting the consideration of the MAF in the REACH risk assessment framework. Inclusion of the MAF would account for the contribution of “coincidental mixtures” to overall risk, potentially resulting in greater controls to substances that contribute disproportionately to the combined risk. Several approaches to determining and applying the MAF have been proposed. The more recent allocation approach highlighted by the DG ENV differs from a simple generic assessment factor by seeking to allocate an acceptable overall mixture risk between substances according to their contribution to that risk. This approach adapts the “risk cup” approach originally developed by the U.S. Environmental Protection Agency in the regulation of pesticides. More information is available in our September 1, 2026, blog item.

New CLP Hazard Classes: The Final Transition Deadline For Existing Substances Is Approaching

The EU’s new hazard classes are approaching the end of their transitional period for substances placed on the EU market and in the supply chain before May 1, 2025. Introduced by the EU Commission Delegated Regulation (EU) 2023/707, the new hazard classes cover the following properties:

• Endocrine disruption (ED) for human health and the environment;

• Persistent, bioaccumulative, and toxic (PBT);

• Very persistent, very bioaccumulative (vPvB);

• Persistent, mobile, and toxic (PMT); and

• Very persistent, very mobile (vPvM).

For substances already placed on the EU market and in the supply chain before May 1, 2025, the final transition deadline is November 1, 2026. From that date, the new classification requirements will apply, and substances must be classified and labeled in accordance with the new hazard classes. Substances first placed on the market from May 1, 2025, have been subject to the new rules from that date.

The approaching deadline is also relevant for REACH registration dossiers. The European Chemicals Agency (ECHA) has made the new hazard classes available in the International Uniform Chemical Information Database (IUCLID) for inclusion in REACH registration dossiers since spring 2024. ECHA states that, after the applicable transition period, it will be mandatory to indicate whether a substance is classified under any of the new hazard classes and provides specific guidance on updating REACH registrations where the self-classification of a substance changes. Importantly, ECHA states that where a substance does not meet the criteria for a new hazard class, the reasons for that conclusion should be included in the registration dosser. As outlined in ECHA’s validation and quality rules for classification and labelling notifications, ECHA’s IUCLID validation rules indicate that the current, default IUCLID entry of “hazard class not assessed” will not be accepted after the applicable transition period.

With the final November 1, 2026, transition deadline for substances approaching, registrants should be reviewing existing dossiers for alignment between the substance’s CLP classification, safety data sheet (SDS), and REACH registration dossier. It is important to ensure that the dossier appropriately records the outcome and basis of the assessment under the new hazard classes. More information is available in our September 15, 2026, blog item.

ECHA Will Hold Webinar To Assist SMEs In Navigating Chemical Regulations

ECHA will hold the second of two webinars on November 5, 2026, aimed at assisting SMEs with meeting chemical regulatory obligations. The webinar, “Applying for reduced fees: what SMEs need to do,” is intended for companies with no prior experience of applying for SME fee reductions or companies that have benefitted from SME fee reductions before but will be using the updated process for the first time. The first webinar, “SME webinar: Steps for notifying to poison centres,” was held September 23, 2026,

ECHA’s focus on supporting SMEs has become an integral part of its work following a July 2025 survey measuring stakeholders’ perceptions of ECHA. Analysis of the survey results suggests that improvements could be made in collaboration and knowledge sharing, enhancing communication and transparency, and driving innovation and efficiency. ECHA also provides the SME Hub, a centralized source of relevant information for SMEs that supports companies to identify their roles in supply chains and determine the associated obligations. An inventory of national support materials in national languages and a multilingual virtual assistant pilot providing quick responses are also provided.

Poison Center Notification Compliance: Distributor Obligations And Clarification Of UFI Requirements For Imported Mixtures

Effective January 1, 2027, distributors will be explicitly identified as duty holders under CLP Article 45. This clarification is intended to provide greater clarity regarding distributors’ responsibilities in supporting Poison Center Notifications (PCN) requirements and to help address information gaps across the supply chain. The clarification is particularly relevant to companies that:

• Sell mixtures in an EU member state and are not covered by an existing notification; or

• Rebrand products under their own name or label.

Companies potentially affected by these requirements should review the updated Steps for industry guidance to determine whether additional actions or notifications may be required beginning January 1, 2027. In addition, a corrigendum to the Guidance on Annex VIII to CLP for PCNs clarifies responsibilities for the labeling of imported mixtures with a Unique Formula Identifier (UFI). The updated text confirms that responsibility for placing the UFI on the product label rests with the EU importer. Where products are labeled before being placed on the EU market, the use of the importer’s UFI is recommended.

MEXICO

New Food Additive Framework

We are pleased to republish this timely item published in the August 24, 2026, issue of Melissa Owen’s “Around Latin America” newsletter.

Mexico’s Federal Commission for Protection against Sanitary Risks (COFEPRIS) published comprehensive new rules on food additives and processing aids on August 21, 2026, fully replacing the framework that had governed food additives, beverages, and food supplements since 2012. The new Agreement enters into force 60 business days after publication (approximately late November 2026).

The Agreement consolidates permitted, restricted, and prohibited additives and processing aids across eleven annexes covering:

• Functional additives with established acceptable daily intakes (ADIs)

• Additives permitted under Good Manufacturing Practices (GMP)

• Colorants with established ADIs

• Colorants permitted under GMP

• Sweeteners

• Enzymes

• Processing aids

• Flavorings

• Additives permitted for infant and follow-on formulas

The substantive framework and categories are broadly consistent with the prior rules, but several changes warrant attention.

Colorant limits tightened. For Annex III colorants — those with established ADIs — where prior rules permitted use according to Good Manufacturing Practices without a specific numerical ceiling, the new Agreement establishes maximum use limits. Companies have 24 months from publication to adapt formulations where needed.

Labeling requirements clarified. Additives must be declared in the ingredient list by common name or a recognized synonym listed in the Agreement. Sweeteners carry additional labeling obligations, including declaration of concentration per serving and the applicable ADI where one exists.

Dynamic update mechanism. The annexes will now be updated every three months on the COFEPRIS website, with the full Agreement republished in the Official Gazette every six months. Companies will need to monitor the COFEPRIS additives page actively rather than relying solely on official publications for compliance purposes.

Transition periods. Products or categories not currently listed in Annexes I, III, or VII that are using additives under the prior framework have 12 months to notify their use under the new Agreement. If COFEPRIS determines the use is not acceptable, companies have an additional 24 months to reformulate. Gold, silver, and aluminum colorants not included in the new text have six months to request inclusion and 18 months to eliminate them from formulations if not included.

Key Takeaway: The 2012 additive framework is gone. Companies should review current formulations against the new annexes before the late November entry into force date, flag any colorants with prior BPF-only approvals that now carry numerical limits, ensure additive labeling meets the new declaration requirements, and set up active monitoring of the COFEPRIS additives webpage since the lists can now change quarterly without a corresponding publication.

Link to Agreement on Food Additives and Processing Aids: https://dof.gob.mx/nota_detalle.php?codigo=5796825&fecha=21/08/2026

UK

UK REACH Update: Transitional Registration Deadlines Deferred

On August 6, 2026, the UK government extended the UK REACH transitional deadlines for any company manufacturing or importing chemicals into Great Britain (GB) (England, Scotland, and Wales). Grandfathered substances now have one of the following deadlines depending upon the hazardous properties and tonnage band.

• October 27, 2029:
  
  
  • Substances that are manufactured or imported at or above 1,000 metric tons per year (mt/y);
    
    
  • Substances that are manufactured or imported at or above one mt/y and classified as CMR;
    
    
  • Substances that are manufactured or imported at or above 100 mt/y and classified as very toxic to aquatic organisms (acute or chronic); and
    
    
  • Substances of very high concern (SVHC) on the Candidate List before December 31, 2023.
    
    
• October 27, 2030:
  
  
  • Substances that are manufactured or imported at or above 100 mt/y; and
    
    
  • SVHCs added to the Candidate List between January 1, 2024, and October 27, 2026.
    
    
• October 27, 2031:
  
  
  • Substances manufactured or imported at or above one mt/y.

The extension was granted to allow the UK government time to develop and legislate the Alternative Transitional Registration model (ATRm), that aims to reduce the data and financial burdens on businesses. The Health and Safety Executive (HSE) has aligned its compliance review timelines with these revised dates.

GB-based downstream users or distributors of EU-registered substances should have submitted a downstream user import notification (DUIN) previously. Notifications may still be submitted if eligible. More information is available in our August 21, 2026, blog item.

GB PIC List Updated

HSE, the Prior Informed Consent (PIC) Designated National Authority (DNA) for GB, will update the GB PIC list from August 28, 2026. Regulation (EU) No 649/2012 of the EP and of the Council of 4 July 2012, also known as the GB PIC list, addresses the export and import of hazardous chemicals. Updates to it ensure that decisions to list chemicals under the Rotterdam Convention’s PIC procedure for certain hazardous chemicals and pesticides in international trade are properly reflected. They also ensure that decisions taken under the Stockholm Convention on Persistent Organic Pollutants (POP) are reflected in the relevant part or parts of the list.

HSE is also updating the part of the GB PIC list that catalogues chemicals and articles that are subject to an export ban under the GB Mercury Regulation. The updated list is available as of August 28, 2026. For the new chemistries included on the list, exporters and importers may be subject to additional obligations under the GB PIC regulation, including annual reporting requirements. Further updates to the other parts of the GB PIC list will be made at a later date.

Defra Launches Technical Consultation On ATRm

Following the UK’s departure from the EU, the government established the independent UK REACH. UK REACH retains both the fundamental approach and key principles of EU REACH and is focused on ensuring that GB continues to uphold high levels of protection for human health and the environment. In response to a consultation held in 2024, the Department for Environment, Food and Rural Affairs (Defra) published its proposed policy approach to the ATRm on March 30, 2026. The proposed ATRm provisions aim to introduce more proportionate requirements for transitional registrations and will:

• Reduce the hazard information routinely submitted at registration;

• Retain the existing use and exposure requirements;

• Align regulatory decisions with EU decisions unless there are compelling reasons to diverge; and

• Provide HSE with targeted powers to request further information where needed.

Defra has launched a technical consultation on the proposed amendments to the legal text of UK REACH required to implement the ATRm. The deadline for providing responses is November 10, 2026. Defra particularly welcomes responses from chemical manufacturers and importers, downstream users, trade associations, environmental and health organizations, legal and regulatory advisers, and others with UK REACH experience. More information is available in our October 5, 2026, blog item.

Navigating A New UK REACH Registration For An Existing Substance Without A Lead Registrant

Following the UK’s exit from the EU, any legal entity based in GB intending to manufacture or import a substance into England, Scotland, and/or Wales at or above one mt/y is required to submit a registration to HSE for that substance. This process is typically straightforward. What should a company do, however, when a substance is identified as a New Registration of an Existing Substance (NRES) and no Lead Registrant has been assigned? The following steps provide a practical guide for navigating this common scenario:

• Prepare and submit an Article 26 Inquiry (Inquiry) for the substance via Comply with UK REACH;

• Await notification from HSE via Comply with UK REACH once the Inquiry dossier has passed the Business Rules, Technical Completeness Check, and Completeness Check. HSE will inform the submitter that the substance is considered a NRES and will place it in the relevant Substance Group with other potential registrants (including registrants that have grandfathered the substance and new registrants that have submitted an Inquiry);

• Prepare and submit a registration dossier. To register, either a Lead or Member Registration dossier with the appropriate data for the tonnage band needs to be submitted. Normally, a Lead dossier would include the relevant test summaries. In the case of NRES dossiers, however, the registrants within the Substance Group will not be in a position to do this. Therefore, ensure that the submitted dossier contains waivers explaining why the submitter is currently unable to provide all relevant test summaries;

• Negotiate with the other members of the Substance Group and determine who will take the role of Lead Registrant; and

• Submit a registration dossier (Lead or Member Registration dossier) via Comply with UK REACH to HSE that complies with the full information requirement for the submitter’s role within the Substance Group and the tonnage band to continue to manufacture or import into GB. Ensure that the dossier is complete by the applicable transitional deadline for the substance based upon its hazard properties and the tonnage band.

Navigating international chemical regulatory requirements and product stewardship initiatives can be challenging. The Acta Group’s (Acta^®) team of professionals closely monitors international regulatory and statutory developments and is well-versed in product stewardship initiatives. Acta welcomes opportunities to assist companies in developing practical compliance strategies and managing evolving compliance obligations.