Overview of EU Obligations 2025/26: What Quality Managers Need to Know Now

Introduction

The EU is tightening its product and environmental law requirements in 2025/26 to enforce a circular economy, transparency, and pollutant minimisation along the supply chain. For manufacturers, this is a key period, as the PPWR (new EU Packaging Regulation) applies from 2026, the CSDDD is being transposed into national law, and the battery passport obligation is scheduled for 2027. The target audience of this overview is quality managers, compliance teams, and manufacturers who must align processes, data, and supplier management accordingly.

REACH 2025 – Chemical Management Tightened

The REACH restriction on intentionally added microplastics (Regulation (EU) 2023/2055) applies with phased transitional periods until 2035, requiring formulations, labelling, and placing on the market to be adapted in 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 obligations for articles containing ≥0.1% w/w SVHC. In parallel, the PFAS group restriction under the REACH procedure is progressing, following the publication of a revised version of the proposal in 2025, which can address tens of thousands of substances.

• Relevance for Manufacturers & Supply Chains: New SVHC listings require material and article screenings, supplier inquiries and, where applicable, SCIP notifications via the ECHA platform for articles containing ≥0.1% w/w SVHC.

• Practical Action Items: Update SVHC/REACH registers, check for 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 updated via exemptions and delegated acts. In 2025, deadlines for exemption renewals以及 new/adapted exemptions are relevant; missed renewals jeopardize compliance and market access.

• Impact on Product Development & Suppliers: Substance compliance must be integrated early into design FMEAs, material approvals, and supplier PPAPs, as RoHS non-compliance directly affects the conformity of electronic assemblies.

• Documentation Obligations: Technical documentation and declarations of conformity must reference RoHS-relevant evidence and, where applicable, exemptions; proactive exemption 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, establishes uniform, binding requirements for sustainable design, minimisation, recycled content, reuse, and labelling. Among other things, it requires material and reuse labelling, digital data carriers (e.g. QR), and clear rules for environmental claims, accompanied by recycled content quotas, particularly for plastic packaging.

• Recycling Rates & Labelling: Packaging must be labelled by material and linked via data carriers to information on reuse/recycling and, where applicable, recycled content to increase sorting and recycling quality.

• Action Steps: Record packaging BOMs, define material labelling and QR data flows, plan artwork rollouts, secure recycled material procurement, and establish claims reviews against greenwashing risks.

EU Battery Regulation

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

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

• Significance for QM & EMS: Auditable data collection across plants, supply chains, and product use is required, including third-party verifications for carbon footprint declarations and fulfillment of efficiency/recovery targets.

CSDDD – Supply Chain Due Diligence

The CSDDD (Directive (EU) 2024/1760) entered into force on 25 July 2024 and will be transposed into national law by 2026/27, with phased obligations starting in 2027 based on company size and turnover. The final compromise covers companies with more than 1,000 employees and €450 million in global turnover, with phase-ins starting in 2027/2028/2029 depending on the threshold; non-compliance can lead to significant regulatory action and fines.

• Risks of Non-Compliance: In addition to regulatory orders, companies face turnover-based fines of up to 5% and civil liability risks for omitted due diligence processes.

• Role of QM in the ESG Context: Quality management should integrate risk analysis, preventive and remedial actions, as well as effectiveness monitoring into processes, 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 will become mandatory on a product-specific, phased basis, starting with priority sectors such as batteries. It is a digitally accessible data collection per product with a unique identifier, providing information on materials, repairability, substances of concern, and compliance, among other things.

• Data to be Provided: Product identifier, compliance documents, material and chemical data, repair and end-of-life information, as well as access mechanisms via QR/NFC per implementing act.

• Integration: Connection to PLM/ERP/MDM and external registers is necessary to keep supply chain data, test reports, and regulatory queries secure, versioned, and accessible in a public or role-specific manner.

Concrete Recommendation Actions for Quality Managers

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

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

• Step 3: Implement RoHS exemption management with deadline monitoring for 2025 and integrate supplier declarations/test reports into the technical documentation.

• Step 4: Launch the PPWR programme: Define material labelling, QR/data carriers, recycled content roadmap, artwork adaptations, and green claims reviews.

• Step 5: Ensure battery passport readiness: Secure CO₂ data per plant/batch, third-party verification, passport data model, and QR processes for EV/industrial batteries >2 kWh by February 2027.

• Step 6: Operationalise the CSDDD due diligence process (policy, risk analysis, measures, complaints mechanism, monitoring, reporting) with supplier audits extending 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 authority portals should be established early. Query automation, validation of test reports, and declarations of conformity can accelerate compliance, for instance through specialized workflows and AI-supported document checks in combined toolchains such as turnus.ai as an orchestrator for data and process integration.

Opportunities Instead of Just Obligations

Those who implement PPWR-compliant packaging, DPP transparency, and low-pollutant materials early unlock cost benefits in end-of-life recovery, reduce re-design risks, and strengthen market access in regulated sectors. Linking quality, compliance, and sustainability along the product lifecycle thus transforms a cost centre into a key differentiator in the EU internal market.

Conclusion

The years 2025/26 mark the transition to significantly stricter, data-driven EU obligations — those who modernise structures, data models, and supplier management now will reduce risks and gain speed in the market. Quality, compliance, and sustainability are merging: anyone who conceives and digitally maps this triad as a system establishes a resilient competitive advantage.