August 2026

The California Department of Toxic Substances Control (DTSC) officially added para-Phenylenediamine (PPD) derivatives to its Candidate Chemicals List. This administrative step does not immediately impose new requirements. The DTSC will now evaluate consumer products containing PPD derivatives for potential future regulatory action.

The Department of Toxic Substances Control (DTSC) in the state of California added para-Phenylenediamine (PPD) derivatives to its Candidate Chemicals List on 3 July 2026, with an effective date of 3 October 2026. This action was taken to address potential environmental exposures. Placing the entire chemical class on the Candidate Chemicals List under the Safer Consumer Products program establishes the foundation for future action, similar to evaluations required under California Proposition 65. This prevents manufacturers from substituting 6PPD with another harmful PPD derivative without evaluating the environmental trade-offs.

Currently, no specific consumer products are subject to new compliance requirements. However, economic operators must inventory their supply chains for all PPD derivatives to prepare for future compliance obligations.

The Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40) entered into force on 11 February 2026 and applies across the European Union (EU), beginning 12 August 2026. Under Article 5 of the PPWR, Regulation EU 2025/40, manufacturers must minimize Substances of Concern (SoCs) in packaging. Aside from established rules for heavy metals and per- and polyfluoroalkyl substances (PFAS), a definitive SoC list does not yet exist.

In July, the European Chemicals Agency (ECHA) invited various packaging stakeholders who had previously provided feedback on the PPWR call to review and comment on the draft list of SoCs under the PPWR.

The draft list contains more than 700 substances identified as SoCs, selected from around 2600 substances found in packaging or packaging waste. The assessment covers both intentionally added substances such as adhesives, coatings, inks, pigments, colorants, antioxidants and other additives, and non-intentionally added substances formed during the production, use or recycling of packaging materials.

ECHA requested the stakeholders provide feedback on:

• The current use of the substance in question in packaging applications: a positive confirmation (or otherwise) of the substance use in packaging materials, types and formats listed

• Whether the substance is an intentionally added substance (IAS) or not

• The packaging material/type/ format the substance is used in

• The technical function of the substance

QIMA will continue to monitor PPWR developments and their potential impacts.

On 11 August 2026, the European Commission (EC) published a draft directive proposing significant amendments to Annex II of the Toy Safety Directive (2009/48/EC), establishing stricter control standards for allergenic fragrances, bisphenol A (BPA), phenol, and benzisothiazolinone (BIT) in toys. The draft is currently open for public consultation, with stakeholders invited to submit comments by 10 October 2026.

Proposed changes:

1. The fragrance Lilial (2-(4-tert-butylbenzyl)propionaldehyde, CAS 80-54-6) is proposed to be removed from the list of “permitted but subject to labeling requirements” and transferred to the prohibited substances list, due to its classification as toxic for reproduction.

2. The old standards EN 71-10/11/12 in the 2009/48/EC Appendix C will be removed and replaced with the new standards. Limit of BPA will be reduced from 0.04 mg/L to 0.005 mg/L, which is aligned with the Toy Safety Standard (Regulation (EU) 2025/2509). The significant reduction in the permitted migration limit for BPA is based on a 2023 European Food Safety Authority (EFSA) scientific opinion.

According to the draft European Commission (EC) schedule, the revision would be entered into force in Q4 2026. Member States are required to transpose the directive into national legislation within 12 months of its publication, and the new rule will be formally effective 12 months after publication.