CH/BAV Legal AI
April 2026
Legal AI: Bernese Bar Association publishes guidance on AI tools for law firms. Hallucinations cannot be ruled out.
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.
Published
10 April 2026. Version 1. Languages: DE/FR.
Key findings
Hallucinations cannot be excluded with current technology. Citations can be invented. Automated anonymisation does not guarantee complete and consistent de-identification. Every output requires manual review.
Vendor questions
Six questions for vendors: hosting location, data access, claimed legal expertise, hallucinations, anonymisation, and evidence of efficiency gains. A seventh item invites firms to share vendor responses with the BAV.
Who is affected
Law firms and legal departments evaluating or using AI-based tools for legal work, document review, or anonymisation.
Action
If a vendor promises legal certainty, perfect anonymisation or zero hallucinations, treat it as a red flag. Use the BAV vendor questions as a structured checklist for AI tool procurement.
Supply Chain
April 2026
Integrated supply chain compliance: eleven laws, one due diligence system. New paper by the Helpdesk on Business and Human Rights.
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.
Published
8 April 2026. Helpdesk on Business and Human Rights, commissioned by BMZ, delivered by DEG Impulse.
Scope
Eleven laws analysed: LkSG, CSDDD, EUDR, EUFLR, EU Battery Regulation, EU Conflict Minerals Regulation, CSRD, CBAM, EU Taxonomy, Empowering Consumers Directive, ESPR.
Key finding
Most instruments build on the same core due diligence logic drawn from the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. An integrated system covering risk analysis, prevention, grievance mechanisms, stakeholder engagement and documentation can satisfy multiple requirements at once.
Who is affected
Companies subject to supply chain due diligence, sustainability reporting, or related obligations under EU or German law. Smaller companies are also affected indirectly through customer requirements and supply chain contracts.
Action
Run one integrated due diligence system instead of treating each new law as a separate project. Use the shared logic across instruments to reduce duplication in risk analysis, prevention, grievance mechanisms and documentation.
CH/NUFG
April 2026
Switzerland: Federal Council opens consultation on the NUFG. Due diligence for around 30 companies, reporting for around 100.
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.
Legal basis
Draft Federal Act on Sustainable Corporate Governance (NUFG). Indirect counter-proposal to the Corporate Responsibility Initiative 2.0. Federal Council decision of 1 April 2026.
Scope
Due diligence obligations for the largest companies, around 30 in total. Sustainability reporting for large companies above 1,000 employees and CHF 450 million turnover, around 100 firms. The draft follows the EU approach after Omnibus.
Liability
Two liability variants are on the table in the consultation.
Deadline
Consultation closes on 9 July 2026.
Who is affected
Large Swiss companies and companies with significant Swiss operations. Smaller companies may be affected indirectly through supply chain requirements.
Action
Check whether the company falls within the scope thresholds for due diligence or sustainability reporting. Review the two liability variants. Consider submitting a response during the consultation period.
PPWR
April 2026
PPWR substances of concern: the PFAS ban is fixed for August 2026. A broader SoC list still depends on the ECHA report.
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.
Legal basis
Regulation (EU) 2025/40, Article 5 on substances of concern, and Article 5(5) on PFAS restrictions in food contact packaging.
What applies from 12 August 2026
PFAS in food contact packaging: max. 25 ppb per individual PFAS (targeted analysis); max. 250 ppb for sum of PFAS.
Heavy metals (Pb, Cd, Hg, Cr VI): combined max. 100 mg/kg in all packaging (unchanged from Directive 94/62/EC).
What is still pending
The Commission and ECHA report on substances of concern in packaging is due by 31 December 2026. It may lead to further restrictions under the PPWR or REACH. Beyond PFAS and heavy metals, no final SoC list exists yet.
ECHA process
The call for evidence on substances in packaging was launched on 17 September 2025 and closed on 28 October 2025. Its results feed into the Commission report due at the end of 2026.
Who is affected
All manufacturers and importers of food contact packaging are directly affected, with immediate attention required for PFAS. Manufacturers of all packaging types should also monitor the wider ECHA and Commission process on substances of concern.
Action
Test food contact packaging for PFAS now using the Commission's stepwise approach (total fluorine screening, then targeted analysis if >50 ppm). Map all substances of concern across packaging portfolio in preparation for the broader SoC report.
PPWR
April 2026
The Commission publishes PPWR guidance and FAQs. This comes 4 months before the application date.
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.
Published
30 March 2026. Commission reference IP/26/664.
Applies from
12 August 2026 for the general application of the PPWR. Further provisions apply in stages through 2040.
Who is affected
All economic operators placing packaging on the EU market, including manufacturers, importers, producers, distributors, and online marketplaces.
Action
The guidance should be reviewed to verify role classification, confirm the PFAS status of food contact packaging, and assess reuse and recyclability obligations before August 2026.
AI Act
April 2026
AI Act: Digital Omnibus proposes to delay high-risk AI deadlines. Trilogue between Parliament and Council begins.
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.
Legal basis
Commission proposal COM(2025) 836, 19 November 2025, amending Regulation (EU) 2024/1689. Council negotiating mandate, 13 March 2026 (consilium.europa.eu). Parliament IMCO/LIBE joint report adopted 18 March 2026. Procedure reference: 2025/0359(COD).
Key proposed changes
Both Parliament and Council propose fixed new application dates for high-risk AI obligations: 2 December 2027 for standalone high-risk AI systems (Annex III) and 2 August 2028 for high-risk AI systems embedded in regulated products (Annex I). High-risk systems lawfully on the market before these dates may remain without re-certification unless significantly changed. The proposal also extends privileges previously reserved for SMEs to small mid-caps (SMCs). A new prohibited practice targeting AI systems generating non-consensual intimate imagery is proposed by both institutions. The Commission's proposal to remove the EU database registration obligation for providers self-assessing their systems as non-high-risk was rejected by both Parliament and Council.
Status
Trilogue negotiations are expected to begin in April 2026. No final text has been adopted. All proposed changes remain subject to amendment in trilogue. The current application date of 2 August 2026 for high-risk AI obligations remains in force until an amending regulation is adopted and enters into force.
Who is affected
Providers and deployers of high-risk AI systems under Annex I and Annex III of Regulation (EU) 2024/1689. Providers of AI systems placed on the market before 2 August 2026 subject to Art. 50(2) marking obligations. Providers of GPAI models regarding AI Office supervision scope.
Action
Monitor trilogue outcome. The current 2 August 2026 deadline for high-risk AI obligations remains legally in force. Compliance planning should not be put on hold pending the final text. Systems already on the market before the new dates, once adopted, are expected to avoid re-certification if no significant design change occurs.
Machinery
April 2026
Machinery Regulation: Commission expert group prepares the application guide. Drafts during 2026, final guide expected towards the end of 2026.
Regulation (EU) 2023/1230 on machinery applies from 20 January 2027. To support consistent application across the EU, the European Commission has set up an Editorial Group for the future application guide. The first meeting was held on 28 January 2025. The work is split between a main editorial group and five subgroups, covering AI-based safety functions, autonomous mobile machines, cybersecurity, digital documentation and other priority topics. According to the Commission expert group work, the guide is expected towards the end of 2026. It will not be legally binding, but it is expected to become an important reference for consistent application, comparable to the Edition 2.3 guide for the Machinery Directive 2006/42/EC.
Legal basis
Regulation (EU) 2023/1230 on machinery. Application from 20 January 2027.
Process
Editorial Group set up by the Commission. First meeting 28 January 2025. Structure: one main editorial group plus five subgroups, covering AI-based safety functions, autonomous mobile machines, cybersecurity, digital documentation and other priority topics. First subgroup drafts are expected during 2026 and will become visible in the Expert Group on Machinery folders.
Status
Work in progress. The application guide is expected towards the end of 2026. It will not be legally binding, but is expected to become an important reference for consistent application across the EU, comparable to the Edition 2.3 guide for the Machinery Directive 2006/42/EC.
Who is affected
Manufacturers, importers, distributors and authorised representatives placing machinery on the EU market, plus notified bodies and market surveillance authorities preparing for application from 20 January 2027.
Action
Watch the drafts as they appear in the Expert Group on Machinery folders. Use the Edition 2.3 guide for Directive 2006/42/EC as a reference baseline for internal preparation work until the new guide is published.
REACH
April 2026
PFHxA: REACH restriction starts to apply. First obligations from 10 April 2026, broad consumer scope from 10 October 2026.
Regulation (EU) 2024/2462 added entry 79 to Annex XVII of the REACH Regulation, restricting undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances. The first obligations apply from 10 April 2026 to firefighting foams used in training, testing and public firefighting services. From 10 October 2026 the scope extends to consumer textiles, leather, furs and hides in clothing and accessories, footwear, paper and cardboard used as food contact materials, consumer mixtures and cosmetic products. Other consumer textiles follow on 10 October 2027. The limits are tight: 25 ppb for PFHxA and its salts, 1,000 ppb for PFHxA-related substances, both measured in homogeneous material.
Legal basis
Regulation (EU) 2024/2462 of 19 September 2024 amending Annex XVII to Regulation (EC) No 1907/2006 (REACH). Entry 79 covers PFHxA, its salts and PFHxA-related substances.
Phased application
10 April 2026: firefighting foams used in training, testing and public firefighting services. 10 October 2026: clothing textiles and accessories, footwear, paper and cardboard used as food contact materials (Reg. (EC) 1935/2004), consumer mixtures and cosmetic products (Reg. (EC) 1223/2009). 10 October 2027: other consumer textiles. 10 October 2029: civil aviation foams.
Limits
In homogeneous material: 25 ppb (parts per billion) for PFHxA and its salts; 1,000 ppb for PFHxA-related substances.
Exemptions
Specific exemptions exist, for example for personal protective equipment within the scope of Regulation (EU) 2016/425 and certain medical devices.
Who is affected
Manufacturers, importers and downstream users of textiles, footwear, food contact paper and cardboard, consumer mixtures, cosmetics, firefighting foams and aviation foams.
Action
Test products against the homogeneous material limits, request supplier statements on PFHxA, salts and related substances, and align procurement and product files with the staged application dates. The dates are fixed.
EUDR
March 2026
EUDR: Commission publishes 3rd edition of the supply chain infographic. Role logic clarified for operators, downstream operators and traders.
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).
Published
25 March 2026. European Commission together with UNEP-WCMC. 3rd edition.
Key message
Operators that place a product on the EU market for the first time carry out full due diligence. Downstream operators and traders only pass on reference numbers. Micro or small primary operators in low-risk countries can file a one-time simplified declaration.
Legal basis
Regulation (EU) 2023/1115 on deforestation-free products, as amended by Regulation (EU) 2025/2650.
Who is affected
Operators, downstream operators, traders and MSPOs placing relevant commodities on the EU market or exporting them from the EU.
Action
Map the transaction. Check who places the product first on the EU market. That decides the duty level. Use the infographic to verify the correct role classification.
Detergents
March 2026
New Detergents Regulation (EU) 2026/405 published. Mandatory Digital Product Passport, extended scope, tighter biodegradability rules from 2032 and 2034.
Regulation (EU) 2026/405 on detergents and surfactants was published in the Official Journal on 2 March 2026 and entered into force on 22 March 2026. It will replace the twenty-year-old Regulation (EC) No 648/2004 from 23 September 2029. The new framework extends the definition of detergent to products containing microorganisms and to fabric care auxiliary products, makes a Digital Product Passport mandatory under Article 21 with technical requirements set out in the regulation, and tightens biodegradability requirements in two stages: from 23 March 2032 for water-soluble polymer films used in detergent capsules and from 23 March 2034 for other organic substances added at concentrations of 10 percent or more by weight. Explicit rules apply to refill sales and online distance selling, and animal testing is generally prohibited. The transition window is three and a half years.
Legal basis
Regulation (EU) 2026/405 of 11 February 2026 on detergents and surfactants. Published in the Official Journal on 2 March 2026 (OJ L 2026/405). Repeals Regulation (EC) No 648/2004 from 23 September 2029.
Application
Entered into force on 22 March 2026. Applies from 23 September 2029. Tightened biodegradability requirements apply from 23 March 2032 for water-soluble polymer films in detergent capsules and from 23 March 2034 for other organic substances at concentrations of 10 percent or more by weight.
Key changes
Extended definition of detergent (microorganisms, fabric care auxiliaries, odour modifying products). Mandatory Digital Product Passport (Art. 21) with technical requirements set out in the regulation. Stricter biodegradability requirements applying in two stages. Explicit rules for refill sales and online distance selling. General prohibition of animal testing.
Who is affected
Manufacturers, importers, distributors and authorised representatives placing detergents and surfactants on the EU market, plus suppliers of microorganism-based products and fabric care auxiliaries newly within scope.
Action
Map the product portfolio against the new scope, prepare for the Digital Product Passport, and align reformulation timelines with the staged biodegradability deadlines in 2032 and 2034.
DPP
March 2026
ISO and IEC announce a new Joint Technical Committee for Digital Product Passport standards.
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.
Status
The creation of ISO/IEC JTC 5 was announced in March 2026. The committee is being established and the relevant standards are in development. CEN/CLC JTC 24 at EU level has already been active since Q3 2023.
Key milestone
The EU digital registry is expected to be operational by July 2026. The first DPP obligations, for batteries, start in February 2027.
Who is affected
All companies preparing DPP implementation, especially technology providers, manufacturers, and compliance teams.
Action
The work of ISO/IEC JTC 5 should be monitored closely. DPP data architecture should be aligned with ISO/IEC 15459:2015 on unique identifiers and with the upcoming interoperability standards.
REACH
March 2026
Universal PFAS restriction. ECHA proposal under review.
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.
Status
The proposal is under review. No binding decision has been taken yet.
Who is affected
Manufacturers using PFAS in products, textiles, coatings, or packaging.
Action
PFAS substance mapping across the supply chain should begin now.
EUDR
April 2026
EUDR: Regulation (EU) 2025/2650 in force; application postponed to 30 December 2026 and 30 June 2027.
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.
Legal basis
Regulation (EU) 2023/1115 on deforestation-free products, as amended by Regulation (EU) 2025/2650, OJ L 2025/2650, 23 December 2025.
New deadlines
30 December 2026 for large and medium operators and traders. 30 June 2027 for micro and small operators.
Key changes
New category of downstream operators with reduced due diligence obligations, identical to those applicable to traders. Only the first operator placing a relevant product on the EU market submits a due diligence statement; downstream operators and traders pass on the reference number. Micro and small primary operators submit a one-off simplified declaration instead of a full due diligence statement. Printed products (books, newspapers, printed pictures) removed from Annex I.
Simplification review
The Commission must carry out a simplification review and present a report by 30 April 2026, assessing administrative burden particularly for micro and small operators. The report may be accompanied by a legislative proposal where appropriate.
Who is affected
Operators and traders placing cattle, cocoa, coffee, palm oil, rubber, soya, wood, and derived products on the EU market or exporting them from the EU.
Recommended actions
The postponement does not remove due diligence obligations for primary operators. Supply chain traceability, geolocation data collection, and risk assessment work should continue. The simplification review due by 30 April 2026 may result in further adjustments, but core obligations are unlikely to change.
GPSR
February 2026
Germany puts the amended Product Safety Act in force. The ProdSG now provides the German enforcement, language and sanction layer for the GPSR.
The amended German Product Safety Act (ProdSG) was published in the Federal Law Gazette on 5 February 2026 (BGBl I 2026 No. 29) and entered into force on 19 February 2026. The core product safety duties for non-harmonised consumer products now come directly from Regulation (EU) 2023/988, the GPSR, applicable since 13 December 2024. The amended ProdSG adds the German enforcement, language and sanction layer. Under the new Section 28(2) ProdSG, 32 violations of Regulation (EU) 2023/988 are classified as administrative offences, with fines up to EUR 10,000, and up to EUR 100,000 in two cases (failures of manufacturers and importers to take corrective action regarding dangerous products). Section 6 requires German language for instructions, safety information and warnings.
Legal basis
Amended Produktsicherheitsgesetz (ProdSG), BGBl I 2026 No. 29 of 5 February 2026. National implementing layer for Regulation (EU) 2023/988 (GPSR), applicable since 13 December 2024.
In force
19 February 2026.
Key elements
Section 6: instructions, safety information and warnings must be provided in German for products covered by Article 2 of the GPSR. Section 28(2): classifies 32 violations of Regulation (EU) 2023/988 as administrative offences. Fines up to EUR 10,000 in most cases, up to EUR 100,000 in two cases relating to corrective action duties of manufacturers and importers in case of dangerous products.
Who is affected
Manufacturers, importers and distributors placing non-harmonised consumer products on the German market, plus authorised representatives and online marketplaces.
Action
Map existing GPSR processes against the German national layer. Verify that instructions, safety information and warnings are available in German. Align internal escalation paths with the corrective action duties backed by the higher fine framework.
ESPR
February 2026
ESPR destruction ban: Commission adopts the two key secondary acts. Large enterprises must have a documented process before 19 July 2026.
Article 25 of the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 prohibits the destruction of unsold consumer products listed in Annex VII (clothing, clothing accessories and footwear). It applies to large enterprises from 19 July 2026 and to medium enterprises from 19 July 2030. Micro and small enterprises are out of scope. On 9 February 2026, the European Commission adopted two key secondary acts: a Commission Delegated Regulation setting out derogations from the prohibition, covering for example products that are dangerous, not legally compliant, damaged or affected by manufacturing defects, and a Commission Implementing Regulation on the details and format for disclosure under Article 24.
Legal basis
Regulation (EU) 2024/1781 (ESPR), Article 25 destruction ban for unsold consumer products listed in Annex VII (clothing, clothing accessories and footwear).
Application
Large enterprises: from 19 July 2026. Medium enterprises: from 19 July 2030. Micro and small enterprises: out of scope.
Secondary acts adopted
9 February 2026: Commission Delegated Regulation setting out derogations from the prohibition, covering for example products that are dangerous, not legally compliant, damaged or affected by manufacturing defects. Same date: Commission Implementing Regulation on the details and format for disclosure of information on discarded unsold consumer products under Article 24.
Who is affected
Large enterprises selling clothing, clothing accessories or footwear in the EU. Medium enterprises preparing for 2030. Micro and small enterprises remain exempt but may be indirectly affected through customer requirements.
Action
Set up a documented destruction prevention and disclosure process before 19 July 2026. Map product flows of unsold items, define decision points for prevention, donation, reuse, recycling or other recovery, and align internal data collection with the Article 24 disclosure format.
CH/Food Contact
February 2026
Switzerland: Declaration of Compliance duty for printed food packaging in force. New Article 35a covers printing inks, printed layers and substances used in manufacture.
The revised Swiss Ordinance on consumer goods (Verordnung über Materialien und Gegenstände, SR 817.023.21) entered into force on 1 February 2026. New Article 35a requires a Declaration of Compliance (DoC) for printing inks, for printed layers as a component of a food-contact article, and for the substances used in their manufacture. The DoC applies at all marketing stages except retail and must be issued by a responsible person. The content follows Annex 15 of the Ordinance. Annex 10 contains the positive list of permitted substances, currently around 1,100 entries (former List B has been removed). The Swiss Packaging Institute SVI, together with its Joint Industry Group and with input from the Federal Food Safety and Veterinary Office (FSVO/BLV), has published a non-binding interpretation guideline to harmonise the DoC information flow.
Legal basis
Ordinance SR 817.023.21 (Bedarfsgegenstände-Verordnung), Article 35a and Annex 15. Annex 10 contains the positive list of permitted substances.
In force
1 February 2026.
Scope
Declaration of Compliance required for printing inks, for printed layers as a component of a food-contact article, and for the substances used in their manufacture. Applies at all marketing stages except retail. Must be issued by a responsible person. Content follows Annex 15.
Positive list
Annex 10 contains the positive list of permitted substances, currently around 1,100 entries. The former List B has been removed.
Industry guidance
The Swiss Packaging Institute SVI, together with its Joint Industry Group and with input from the FSVO/BLV, has published a non-binding interpretation guideline to harmonise the DoC information flow along the value chain.
Who is affected
Manufacturers and suppliers of printing inks and printed layers used on food-contact articles, brand owners placing printed food packaging on the Swiss market, and substance suppliers along the supply chain (excluding retail).
Action
Set up DoC templates aligned with Annex 15. Verify that all substances used are covered by the Annex 10 positive list. Use the SVI guideline to align information flow across the supply chain.
Toys
January 2026
New Toy Safety Regulation (EU) 2025/2509. The DPP replaces the Declaration of Conformity.
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.
In force
1 January 2026.
Applies from
The Regulation entered into force on 1 January 2026.. The Toy Safety Directive is repealed 54 months later, which places full application around mid 2030.
Who is affected
Manufacturers, importers, distributors, and online marketplaces selling toys for children under 14 in the EU.
Action
DPP infrastructure should be planned early. Chemical formulations should be checked against the new prohibited substance lists. Obligations for connected toys should be reviewed in light of AI Act alignment.
BWBR
April 2026
Battery Regulation: labelling under Art. 13(1)–(3) delayed beyond August 2026. Implementing act under Art. 13(10) overdue.
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.
Legal basis
Regulation (EU) 2023/1542, Art. 13(1)–(3) and Art. 13(10). Art. 13(6) on the QR code. Art. 77 on the Battery Passport. Draft implementing act on record from 15 December 2025, Ref. Ares(2025)11169592.
Key dates
Labelling under Art. 13(1)–(3): 18 August 2026 or 18 months after the implementing act under Art. 13(10) enters into force, whichever is later. Implementing act not yet in force (as of April 2026); actual application date expected late 2027 or early 2028. 18 February 2027: QR code under Art. 13(6) and Battery Passport under Art. 77 for LV batteries, industrial batteries with a capacity exceeding 2 kWh, and EV batteries. These dates remain legally unchanged in the current regulation text.
Who is affected
Economic operators placing or making available batteries on the EU market, in particular manufacturers, importers, and distributors, each within the scope of the obligations assigned to them under the regulation.
Action
Monitor entry into force of the implementing act under Art. 13(10). Start planning Battery Passport infrastructure now. The QR code and passport system must be fully operational at the moment of market placement from February 2027.
NLF
November 2025
European Product Act. The Commission is consulting on an overhaul of the NLF, CE marking, and market surveillance.
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.
Source
The Commission launched two public consultations on 12 November 2025. One covers the New Legislative Framework, and the other covers the Market Surveillance Regulation.
Consultations
The consultations covered the New Legislative Framework, Decision No 768/2008/EC, and the Market Surveillance Regulation, Regulation (EU) 2019/1020. Both ran until 4 February 2026.
Key objectives
Simplify documentation and conformity assessment obligations
Clarify rules for refurbished, remanufactured and second-life products
Integrate Digital Product Passport as central compliance tool across CE-marked products
Strengthen market surveillance and enforcement, including for e-commerce imports
Align definitions across 30 NLF-based legislative acts
Timeline
Legislative proposal expected Q3 2026. Part of Commission Work Programme 2026.
Who is affected
All manufacturers, importers and distributors placing CE-marked products on the EU market . the NLF underpins RED, LVD, EMC, Machinery, PPE, PED, MDR and 22 other EU product acts
Action
Monitor Commission legislative proposal expected Q3 2026. Begin assessing DPP readiness as a replacement for Declaration of Conformity across your product portfolio.
RED
August 2025
RED Art. 3(3)(d)(e)(f). Cybersecurity requirements are now mandatory for internet connected radio equipment.
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.
Legal basis
Commission Delegated Regulation (EU) 2022/30 of 29 October 2021, supplementing RED 2014/53/EU, Art. 3(3)(d)(e)(f). Published OJ 12 January 2022. Applicable from 1 August 2025 (postponed from 1 August 2024 by Delegated Regulation (EU) 2023/2444).
Requirements
Art. 3(3)(d): device must not harm the network or misuse network resources
Art. 3(3)(e): protection of personal data and privacy of user and subscriber
Art. 3(3)(f): protection from fraud (applies where device enables monetary transactions)
Harmonised standards
EN 18031-1, EN 18031-2, EN 18031-3 . published OJ 30 January 2025 (Implementing Decision (EU) 2025/138). Listed with restrictions . full presumption of conformity only if all applicable clauses are met. Non-compliant with restrictions: Notified Body route required.
Next step
Delegated Regulation (EU) 2022/30 repealed 11 December 2027 . replaced by Cyber Resilience Act (EU) 2024/2847 obligations from that date.
Who is affected
Manufacturers, importers and distributors of internet-connected radio equipment . IoT devices, wearables, smart toys, connected home equipment, industrial radio equipment with internet connectivity
Action
Verify scope of Delegated Regulation (EU) 2022/30 for your product. Assess EN 18031 restrictions. Confirm Module A self-declaration path or initiate Notified Body procedure. Prepare for CRA transition from December 2027.
PPWR
August 2025
PPWR enters into force. The transitional periods begin.
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.
In force
11 February 2025
Applies from
12 August 2026 (most provisions); EPR obligations phased 2026–2030
Who is affected
Manufacturers, importers, distributors placing packaged products on the EU market
Action
Map your packaging portfolio, identify producer roles, prepare for EPR registration
RED
August 2025
USB C common charger requirement. Full scope applies from 2026.
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.
Applies from
28 Dec 2024 (most devices); 28 April 2026 (laptops)
Who is affected
Manufacturers and importers of portable consumer electronics
Action
Verify product scope, update technical documentation and declaration of conformity
AI Act
August 2025
AI Act: GPAI obligations in force from 2 August 2025. Final Code of Practice and Commission guidelines published.
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.
Legal basis
Regulation (EU) 2024/1689, Chapter V (Art. 51 to 56) on GPAI models. GPAI Code of Practice published by the AI Office on 10 July 2025. Commission guidelines on the scope of GPAI obligations published on 18 July 2025. The Commission and the AI Board presented the Code as an adequate voluntary tool to help demonstrate compliance.
Key dates
2 August 2025: GPAI obligations apply to all models placed on the market from this date. 2 August 2027: deadline for compliance for GPAI models already on the market before 2 August 2025. 2 August 2026: full Commission enforcement powers become applicable.
Who is affected
Providers placing GPAI models on the EU market. The guidelines define GPAI models by reference to significant generality and the ability to perform a wide range of distinct tasks. A training compute threshold of 10²³ FLOP is used as an indicative criterion. Downstream providers that significantly modify a GPAI model may also become providers under the Act. Open-source GPAI models are generally exempt, except for models with systemic risk.
Action
Assess whether models in scope qualify as GPAI under the Commission guidelines. Consider signing the Code of Practice as a voluntary tool to help demonstrate compliance. Providers of models with systemic risk (training compute exceeding 10²⁵ FLOP) must notify the AI Office. Providers not using the Code should be able to explain how they otherwise comply.
ESPR
April 2025
The first ESPR working plan has been adopted. Priority product groups are confirmed.
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.
Adopted
16 April 2025
Who is affected
Manufacturers of textiles, electronics, furniture, tyres, steel, detergents
Action
Check if your product category is in the first working plan and monitor upcoming delegated acts
AI Act
February 2025
AI Act. The rules on prohibited practices now apply.
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.
Applies from
2 February 2025 (prohibited practices); 2 August 2025 (GPAI models)
Who is affected
Providers and deployers of AI systems in the EU
Action
Audit AI systems in use for prohibited practice compliance
CPR
January 2025
New Construction Products Regulation (EU) 2024/3110. This is a full recast, not just an amendment.
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.
Published
Published in the Official Journal on 18 December 2024. In force since 7 January 2025.
Applies from
Most provisions apply from 8 January 2026. Penalties under Article 92 apply from 8 January 2027. The old CPR 305/2011 is fully repealed from 8 January 2040.
Key changes
Mandatory declaration of Global Warming Potential (GWP) from January 2026 (Annex II a–d)
Expanded sustainability indicators from January 2030 (Annex II e–m)
Full life cycle environmental reporting from January 2032 (Annex II a–s)
Legal basis for Digital Product Passports — details via delegated acts expected post-2026
37 product families in Annex IV replacing old product families
Strengthened market surveillance and enforcement with penalties
Parallel regime
The old CPR 305/2011 continues to apply for products still covered by harmonised standards under the previous regime until new harmonised standards are issued under the new CPR.
Who is affected
Manufacturers, importers, and distributors of products intended for permanent incorporation into buildings or civil engineering works in the EU.
Action
The relevant product family should be identified in Annex IV. Companies should check whether harmonised technical specifications already exist under the new CPR and prepare for the first sustainability related obligations from January 2026.
GPSR
December 2024
GPSR replaces the GPSD. It adds new obligations for online marketplaces.
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.
Applies from
13 December 2024.
Who is affected
All economic operators, online marketplace operators, and importers without an EU establishment.
Action
The setup for the EU Responsible Person should be reviewed. Technical documentation and recall procedures should also be updated.
Machinery
July 2023
New Machinery Regulation (EU) 2023/1230. It replaces Machinery Directive 2006/42/EC from January 2027.
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.
Published
Published in the Official Journal on 29 June 2023. In force since 19 July 2023.
Applies from
20 January 2027 is the hard application date. There is no transitional overlap after that point. Machinery Directive 2006/42/EC remains applicable until 19 January 2027.
Key changes
Directive → Regulation: directly binding, no national transposition, uniform application across all EU states
AI and cybersecurity: first machinery legislation to include explicit requirements for AI-integrated and digitally connected machinery
Control systems: new requirements for safety-related control systems including traceability log for safety software versions
Digital instructions: manufacturers may now provide user instructions in digital format
Importer and distributor obligations: aligned to New Legislative Framework (NLF) — new obligations for importers and distributors previously not applicable under the Directive
Annex I (high-risk machinery): six categories requiring mandatory third-party conformity assessment — applying harmonised standards does not remove this obligation
Substantial modification: clarified definition — modifiers may become manufacturers with full obligations
Market surveillance: strengthened procedures and updated conformity assessment routes
Who is affected
Manufacturers, importers, and distributors of machinery, related products, safety components, partly completed machinery, and interchangeable equipment placed on the EU market.
Action
A gap analysis against the essential requirements of the new Regulation should be carried out, especially for control systems, AI and cybersecurity, and documentation formats. It should also be checked whether the product falls under Annex I and therefore requires mandatory third party conformity assessment.