CH/BAV Legal AI

Merkblatt No. 4 of the Bernese Bar Association (BAV), published on 10 April 2026, assesses AI tools for law firms. It states that hallucinations cannot currently be ruled out, citations may not exist, and automated anonymisation does not guarantee complete, consistent replacement of personal data. The paper sets out six vendor questions covering hosting location, data access, claimed legal expertise, hallucinations, anonymisation and evidence of efficiency gains, plus a seventh item inviting firms to share vendor responses back with the BAV. Editor: BAV. Author: Dr. iur. Jan Reinhardt.

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Supply Chain

A 2026 paper by the Helpdesk on Business and Human Rights, commissioned by the German Federal Ministry for Economic Cooperation and Development (BMZ) and delivered by DEG Impulse, analyses eleven laws and regulations relevant to sustainable supply chains, among them LkSG, CSDDD, EUDR, EUFLR, EU Battery Regulation, EU Conflict Minerals Regulation, CSRD, CBAM, EU Taxonomy, Empowering Consumers Directive and ESPR. The paper shows that most of these instruments build on the UN Guiding Principles and the OECD Guidelines and recommends an integrated due diligence approach to avoid duplicated work.

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CH/NUFG

On 1 April 2026, the Swiss Federal Council adopted the decision to open consultation on the draft Federal Act on Sustainable Corporate Governance (NUFG), an indirect counter-proposal to the Corporate Responsibility Initiative 2.0. The Federal Council's press release refers to around 30 large companies in scope for due diligence and around 100 companies in scope for sustainability reporting, down from about 200 today. The draft contains two liability variants. The consultation runs until 9 July 2026.

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PPWR

Regulation (EU) 2025/40 introduces two separate layers of chemical restrictions for packaging. The first is already fixed in law. From 12 August 2026, food contact packaging may not contain PFAS above defined thresholds. The second layer is broader and still under development. It concerns substances of concern across packaging types. ECHA launched a call for evidence in September 2025, and the Commission, supported by ECHA, must submit a report by 31 December 2026. That report may lead to further restrictions under the PPWR or REACH. Until then, the broader SoC framework remains open.

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PPWR

On 30 March 2026, the European Commission published its first comprehensive guidance package for Regulation (EU) 2025/40. It includes an interpretative guidance document, an annex, and a FAQ catalogue. The package addresses key areas that required clarification before August 2026. These include the definition of packaging, role allocation across the supply chain, PFAS restrictions for food contact packaging, recyclability timelines, packaging minimisation, reuse targets, and the relationship between the PPWR and the Single Use Plastics Directive. The guidance does not amend the regulation, but it provides the Commission’s interpretation to support more consistent application across the EU.

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AI Act

On 19 November 2025, the Commission published a proposal to amend Regulation (EU) 2024/1689 (Digital Omnibus on AI, COM(2025) 836). The proposal addresses implementation challenges identified since the AI Act entered into force. The Council adopted its negotiating mandate on 13 March 2026. The European Parliament's IMCO and LIBE committees adopted their joint position on 18 March 2026, with a plenary vote on 26 March 2026. Trilogue negotiations between Parliament, Council, and Commission are expected to begin in April 2026. No final text has been adopted as of April 2026.

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EUDR

On 25 March 2026, the European Commission together with UNEP-WCMC published the 3rd edition of the EUDR supply chain infographic. It reflects the amendments introduced by Regulation (EU) 2025/2650 and explains how obligations are allocated across operators, downstream operators, traders and micro or small primary operators (MSPOs).

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DPP

ISO and IEC have established a new Joint Technical Committee, ISO/IEC JTC 5, for Digital Product Passport standards. The committee focuses on cross sector interoperability, the DPP system framework, and the wider DPP ecosystem. Eight harmonised standards for DPP data and interoperability are expected by 2026. These standards are intended to support the technical infrastructure required for ESPR related DPP obligations from 2027 onwards. The EU digital registry is expected to be operational by July 2026.

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REACH

ECHA’s universal restriction proposal for PFAS under REACH is moving through the regulatory process. If adopted, it would become one of the broadest chemical restrictions in EU history and would affect a very large number of product categories. A final decision is not expected before 2026 or 2027.

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EUDR

Regulation (EU) 2025/2650, published in the Official Journal on 23 December 2025, amends Regulation (EU) 2023/1115 on deforestation-free products. The application date is postponed to 30 December 2026 for large and medium operators and traders, and to 30 June 2027 for micro and small operators. The amendment introduces a new category of downstream operators with reduced obligations, and requires the Commission to carry out a simplification review and present a report by 30 April 2026.

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Toys

Regulation (EU) 2025/2509 was published in December 2025 and entered into force on 1 January 2026.. It replaces the Toy Safety Directive and introduces a mandatory Digital Product Passport for toys. The DPP must be accessible through a QR code, registered in the EU digital registry, and kept available for ten years after market placement. The regulation also tightens chemical requirements and introduces additional implications for connected and AI integrated toys.

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BWBR

Article 13(10) of Regulation (EU) 2023/1542 required the Commission to adopt harmonised specifications for labelling under Article 13(1)–(3) by 18 August 2025. That deadline was not met. A draft is on record in the procedure as of 15 December 2025 (Ref. Ares(2025)11169592). Until the implementing act enters into force, the 18-month period has not started. The application of labelling obligations under Article 13(1)–(3) therefore extends beyond 18 August 2026. The actual start date depends on when the implementing act enters into force and is likely to be late 2027 or early 2028. The dates set out in the regulation for the QR code under Article 13(6) and the Battery Passport under Article 77 are not legally affected by this.

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NLF

In November 2025, the European Commission launched two public consultations that are expected to feed into the planned European Product Act. One covers the New Legislative Framework. The other covers the Market Surveillance Regulation. The initiative is important because any reform of the NLF is likely to affect a large number of EU product laws. The Commission has also signalled that Digital Product Passports are expected to become a central compliance tool for CE marked products.

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RED

Commission Delegated Regulation (EU) 2022/30, supplementing Directive 2014/53/EU (RED), has been applicable since 1 August 2025. It activates the essential requirements of Article 3(3)(d), (e) and (f) of the RED for defined categories of radio equipment . any device capable of communicating over the internet, whether directly or via another device. This includes smartphones, tablets, IoT devices, wearables, smart toys, and connected industrial equipment. The requirements cover protection of the network from harm, protection of personal data and privacy, and fraud prevention. Harmonised standards EN 18031-1, -2 and -3 were published in the Official Journal on 30 January 2025, but come with restrictions . manufacturers must carefully assess whether their product meets all conditions for self-declaration or whether Notified Body involvement is required. Delegated Regulation (EU) 2022/30 is scheduled for repeal on 11 December 2027, when the Cyber Resilience Act (EU) 2024/2847 takes over.

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PPWR

Regulation (EU) 2025/40 on Packaging and Packaging Waste entered into force on 11 February 2025. It will generally apply from 12 August 2026. Extended producer responsibility (EPR) obligations are phased between 2026 and 2030.

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RED

Under the Radio Equipment Directive amendment, USB-C charging became mandatory for most portable electronic devices from 28 December 2024. Laptops follow from 28 April 2026. The regulation covers smartphones, tablets, cameras, headphones, portable speakers and handheld game consoles.

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AI Act

The obligations for providers of general-purpose AI (GPAI) models under Regulation (EU) 2024/1689 became applicable on 2 August 2025. The European AI Office published the final GPAI Code of Practice on 10 July 2025. On 18 July 2025, the Commission published guidelines on the scope of GPAI obligations. The Code is voluntary and has been presented by the Commission and the AI Board as an adequate voluntary tool to help demonstrate compliance. GPAI models placed on the market before 2 August 2025 have until 2 August 2027 to comply.

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ESPR

The European Commission adopted the first ESPR working plan on 16 April 2025, covering a minimum of three years. Priority product groups include textiles, electronics, furniture, tyres, detergents and steel. The plan sets the timeline for delegated acts that will establish product-specific ecodesign requirements.

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AI Act

From 2 February 2025, the rules on prohibited AI practices under Regulation (EU) 2024/1689 became applicable. These cover, among other things, AI systems using subliminal or manipulative deceptive techniques, exploiting vulnerabilities, or enabling social scoring. Obligations for general-purpose AI models apply from 2 August 2025.

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CPR

Regulation (EU) 2024/3110 was published in the Official Journal on 18 December 2024 and entered into force on 7 January 2025. It fully repeals and replaces CPR 305/2011. It is a comprehensive recast. It adds mandatory sustainability indicators, a legal basis for Digital Product Passports, stronger CE marking rules, and a revised framework for market surveillance and enforcement.

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GPSR

The General Product Safety Regulation (EU) 2023/988 became fully applicable on 13 December 2024. and replaced the General Product Safety Directive. Key changes include mandatory internal accident reporting, new obligations for online marketplace operators, and stricter requirements for the EU Responsible Person.

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Machinery

Regulation (EU) 2023/1230 was published on 29 June 2023 and entered into force on 19 July 2023. It replaces the Machinery Directive fully. It applies from 20 January 2027 with no overlapping transitional regime after that date. It is also the first EU machinery legislation to address AI, cybersecurity, and digitally connected systems explicitly.

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