Introduction

In 2025/26, the EU is tightening its product and environmental regulations to enforce circular economy, transparency, and pollution minimisation along the supply chain. This period is crucial for manufacturers as the PPWR (new EU Packaging Regulation) comes into effect in 2026, the CSDDD is transposed into national law, and the battery passport obligation is due in 2027. This overview targets quality managers, compliance teams, and manufacturers who need to align their processes, data, and supplier management accordingly.

REACH 2025 – Strengthened Chemicals Management

The REACH restriction on intentionally added microplastic particles (Regulation (EU) 2023/2055) has staggered transition periods until 2035, requiring adjustments in formulations, labelling, and marketing across numerous product groups. In 2025, the candidate list of SVHCs was expanded in two rounds (January and June), triggering additional information and, if applicable, SCIP notification requirements for articles with ≥0.1% w/w SVHC. Concurrently, the PFAS group restriction is advancing in the REACH process, after a revised proposal capable of addressing tens of thousands of substances was published in 2025.

• Relevance for Manufacturers & Supply Chains: Additions to the SVHC list require material and article screenings, supplier inquiries, and potentially SCIP notifications via the ECHA platform for articles with ≥0.1% w/w SVHC.

• Practical To-dos: Update SVHC/REACH registers, examine the presence of microplastics in formulations, establish SCIP data flows via IUCLID, and proactively assess PFAS risks in materials, coatings, and processes.

RoHS 2025 – Focus on Electronics

The RoHS Directive continues to restrict ten substances (including lead, cadmium, Hg, Cr(VI), PBB, PBDE, DEHP, BBP, DBP, DIBP) in electrical and electronic equipment and is extended via exemptions and delegated acts. In 2025, deadlines for exemption renewals as well as new/adapted exemptions are relevant; missed renewals jeopardise compliance and market access.

• Impacts on Product Development & Suppliers: Substance compliance must be integrated early in design FMEAs, material approvals, and supplier PPAPs, as RoHS violations directly affect the compliance of electronic assemblies.

• Documentation Requirements: Technical files and declarations of conformity must reference RoHS-related evidence and potentially exemptions; proactive exemptions management reduces re-design risks.

PPWR – EU Packaging Regulation

The new EU Packaging Regulation as Regulation (EU) 2025/40 replaces the Directive and from 2026 introduces uniform, mandatory requirements for sustainable design, minimisation, recycled content, reuse, and labelling. It demands, among other things, material and reuse labelling, digital carriers (e.g., QR) and clear rules for environmental claims, complemented by recycled content quotas, especially for plastic packaging.

• Recycling Quotas & Labelling: Packaging must be labelled in relation to the material and linked through data carriers with information on reuse/recycling and potentially recycled content, to improve sorting and circular quality.

• Implementation Steps: Capture packaging BOMs, define material labelling and QR data flows, plan artwork rollouts, ensure recycled material procurement, and anchor claims reviews to protect against greenwashing risks.

EU Battery Regulation

Regulation (EU) 2023/1542 establishes carbon footprint, due diligence, collection and recycling targets, as well as comprehensive information obligations for battery lifecycles. From 1 February 2027, the digital battery passport becomes mandatory for EV and industrial batteries >2 kWh, accessible via unique identifier/QR and with phased requirements until 2030+.

• Traceability: The passport provides data on origin, material composition, CO₂ footprint, recycling, and safety, increasing transparency for market surveillance, workshops, and recycling systems.

• Significance for QM & EMS: Audit-capable data collection across plants, supply chains, and product usage is required, including third-party verification for carbon footprint declarations and achievement of efficiency/recovery targets.

CSDDD – Due Diligence in the Supply Chain

The CSDDD (Directive 2024/1760) came into force on 25 July 2024 and will be transposed nationally by 2026/27, with staggered obligations from 2027 based on company size and turnover. The final compromise covers companies with 1,000 employees and €450 million turnover worldwide, with phase starts in 2027/2028/2029 depending on the threshold; non-compliance can result in significant regulatory measures and fines.

• Risks of Non-compliance: In addition to regulatory orders, turnover-based fines of up to 5% and civil liability risks for neglected due diligence processes are possible.

• Role of QM in ESG Context: Quality management should anchor process-oriented risk analysis, prevention and corrective measures, and effectiveness checks, and scale supplier audits beyond Tier-1.

Digital Product Passport (DPP)

The DPP is introduced by the Ecodesign for Sustainable Products Regulation (ESPR, 2024) and is gradually becoming mandatorily product-specific, starting with priority sectors like batteries. It is a digitally accessible data collection per product with a unique identifier, providing information on materials, repairability, substances of concern, and compliance.

• What Data to Provide: Product identifier, compliance documents, material and chemical data, repair and end-of-life information, and access mechanisms via QR/NFC per implementation act.

• Integration: Connection to PLM/ERP/MDM and external registers is necessary to keep supply chain data, test reports, and regulatory retrievals secure, versioned, and publicly/role-specifically accessible.

Concrete Action Recommendations for Quality Managers

• Checklist Step 1: Update the legal register for 2025/26 (REACH including microplastics, RoHS exemptions, PPWR, BattVO, CSDDD, ESPR/DPP) and map responsibilities, deadlines, evidence.

• Step 2: Harmonise material and article BOMs, establish SVHC screening, and set up SCIP workflow with IUCLID for articles with ≥0.1% w/w SVHC.

• Step 3: Introduce RoHS exemptions management with deadline monitoring in 2025 and integrate supplier declarations/test reports into the technical documentation.

• Step 4: Launch PPWR program: Define material labelling, QR/data carriers, recycled content quotas roadmap, artwork adjustments, and green claims review.

• Step 5: Check battery passport readiness: Secure CO₂ data per plant/lot, third verification, passport data model, and QR processes for >2 kWh EV/industrial batteries by 02/2027.

• Step 6: Operationalise the CSDDD due diligence process (policy, risk analysis, measures, complaints mechanism, monitoring, reporting) with supplier audits beyond Tier-1.

Digital Tools & Automation

Digital product passports and open data approaches require structured, interoperable data systems; therefore, PLM/ERP with DPP-capable data models, QR/NFC carriers, and interfaces to regulatory portals should be established early. Automation of supplier questionnaires, test report validation, and declarations of conformity can accelerate compliance, for example, through specialised workflows and AI-supported document review in combined toolchains such as turnus.ai as an orchestrator for data and process integration.

Opportunities Instead of Just Obligations

Those who realise PPWR-compliant packaging, DPP transparency, and low-pollutant materials early will gain cost advantages in recycling, reduce re-design risks, and strengthen market access in regulated industries. The integration of quality, compliance, and sustainability along the product lifecycle thus transforms from a cost factor to a differentiator in the EU internal market.

Conclusion

The years 2025/26 mark the transition to significantly stricter, data-driven EU obligations – those who now modernise structures, data models, and supplier management will reduce risks and gain speed in the market. Quality, compliance, and sustainability are converging: those who think of this triad as a system and digitally implement it, create a robust competitive advantage.