Chemical compliance deadlines in 2025–2026 are unusually concentrated. Several major frameworks are reaching enforcement milestones simultaneously — the US TSCA PFAS reporting window, a K-REACH SDS format changeover in Korea, phased UK REACH registration deadlines, and the ongoing EU REACH 2.0 revision process — while Japan's GHS SDS mandate has already come into force. Each of these sits within a broader enforcement environment where import bans, penalty notices, and border detentions are the primary consequences of non-compliance.
The common thread across all markets is accelerating regulator action on PFAS, SVHCs, and hazard communication. Businesses that treat chemical compliance as a one-time registration task rather than a continuous operational programme are increasingly exposed. Here is the current enforcement calendar, organised by jurisdiction.
United States — TSCA
13 April – 13 October 2026 — TSCA PFAS Reporting Window Opens
Under Section 8(a)(7) of the Toxic Substances Control Act, the EPA's final PFAS reporting rule requires manufacturers and importers of PFAS-containing articles and chemical substances to submit data on PFAS use, volumes, exposure, and disposal for the period 2011–2022. The six-month reporting window opens on 13 April 2026 for most manufacturers, with a later deadline of 13 April 2027 for small manufacturers and article importers.
PFAS reporting covers over 1,400 individual substances across the PFAS structural class — including fluoropolymers used in industrial coatings, surfactants, and processing aids. Non-reporting carries civil penalties of up to $48,500 per day per violation under TSCA. Many businesses are discovering mid-audit that PFAS are present in supply chain inputs they did not previously track. Proactive supply chain disclosure requests and substance screening should be completed well before the window opens to avoid rushed submissions with incomplete data.
18 May 2026 — TSCA TCE Risk Management Rule Takes Effect
The EPA's risk management rule for trichloroethylene (TCE) under TSCA Section 6(a) establishes a prohibition on manufacture, processing, distribution, and use of TCE across the vast majority of industrial and commercial applications. The rule's compliance deadline for most affected uses is 18 May 2026, with a phased transition of 12–24 months for some categories. TCE has been widely used as an industrial solvent, degreaser, and intermediate in the manufacture of refrigerants and other chemicals.
Businesses must conduct a full inventory audit of TCE use across their own operations and supply chains, identify alternative chemistries or processes, and implement substitution before the compliance date. Continued use after 18 May 2026 in prohibited applications will constitute a TSCA violation. The rule reflects a broader EPA pattern of using Section 6 unreasonable risk determinations to mandate phaseouts rather than simply requiring additional controls.
European Union — REACH
2026 onwards — EU REACH 2.0 Revision: Adoption Timeline
The European Commission published its REACH revision proposal in April 2025, the most significant overhaul of the EU's chemical regulatory framework since the original REACH regulation came into force in 2007. The proposal introduces generic risk assessment approaches for substance groups, expands the SVHC and Authorisation List criteria, and proposes a restructured Registration dossier format. The Regulatory Scrutiny Board issued a negative opinion on the proposal's impact assessment in September 2025, requiring the Commission to revise it before advancing.
The current trajectory points to co-legislative adoption in 2026 or 2027, with transitional periods before the new requirements apply. Businesses should monitor the legislative calendar and begin internal readiness assessments for how a group-based registration approach would affect their chemical portfolios. The revision process does not pause existing REACH obligations — SVHC candidate list additions continue, Authorisation List deadlines remain in force, and substance evaluation commitments under CoRAP proceed on their existing timelines.
2027–2029 — EU PFAS Annex XVII Restriction: Regulatory Timeline
ECHA's universal PFAS restriction proposal under REACH Annex XVII — covering approximately 10,000 PFAS substances — was submitted for SEAC and RAC scientific committee review in 2023. A final Agency opinion is expected in 2026–2027, after which the Commission must propose and adopt the restriction through the regulatory committee process. Implementation is not expected before 2028–2029, with derogations for certain essential uses likely extending beyond that.
Despite the extended timeline, PFAS restriction planning should begin now. The restriction, if adopted in its current scope, would prohibit the manufacture, use, and placement on market of PFAS across virtually all industrial sectors. Many supply chain substitution programmes for PFAS alternatives take 3–5 years to complete when testing, validation, and customer qualification are included. Businesses that delay PFAS mapping and alternative assessment until the formal adoption risk missing the transition window entirely.
United Kingdom — UK REACH
2026 / 2028 / 2030 — UK REACH Registration Deadline Phases
UK REACH — the post-Brexit independent chemical registration regime administered by the HSE — requires manufacturers and importers to submit full registration dossiers for substances they supply into Great Britain. Registration deadlines are phased by tonnage band and hazard profile: high-volume and hazardous substances in the first phase (2026), medium-volume substances in the second phase (2028), and lower-volume substances in the final phase (2030).
Unlike EU REACH, which allows downstream users to rely on their supplier's registration, UK REACH requires GB-based downstream users and importers to be listed on registrations or to submit their own dossiers. Businesses that relied on EU-based Only Representatives for their EU REACH compliance cannot automatically transfer that status to UK REACH — a separate UK OR or direct registration is required. The HSE has issued enforcement guidance making clear that substances supplied after deadline without a valid registration will be treated as non-compliant, creating import risk for non-GB manufacturers.
Asia-Pacific
1 July 2026 — K-REACH Korea: Mandatory GHS SDS Format Takes Effect
South Korea's Chemical Substances Control Act (CSCA) and the Act on Registration and Evaluation of Chemical Substances (K-REACH) require Safety Data Sheets to be prepared in compliance with Korea's specific GHS SDS format requirements. From 1 July 2026, the legacy MSDS format used under the older Occupational Safety and Health Act is no longer accepted — all SDS submitted for workplace communication and import compliance must follow the revised GHS format aligned with the 9th Revised Edition of the UN GHS.
Korea's SDS requirements include specific section ordering, Korean-language content, CAS number disclosure, and hazard classification aligned with K-REACH's designated substance lists. Importers supplying chemical products into Korea must ensure their SDS are updated before 1 July 2026. Enforcement action — including import stops and administrative penalties — applies from that date. K-REACH 2025 structural amendments also introduced new requirements for SDS electronic transmission to downstream users.
April 2025 — Japan ISHL GHS SDS Mandate: Now in Force
Japan's Industrial Safety and Health Law (ISHL) amendments that took effect in April 2025 extended mandatory GHS-compliant SDS and labelling requirements to an expanded list of designated chemical substances. Under the amended framework, manufacturers and importers of covered substances must provide GHS-format SDS to all downstream recipients at the point of supply — the previous exemption for substances below certain concentration thresholds in mixtures has been narrowed significantly.
For importers supplying into Japan, the obligation sits with the entity placing the substance or mixture on the Japanese market. Non-compliant SDS — including legacy MSDS in older Japanese formats or translated EU SDS without adaptation to Japanese GHS requirements — do not satisfy the obligation. The Ministry of Health, Labour and Welfare has authority to issue compliance orders and public disclosure of violations, which creates reputational exposure beyond the immediate regulatory penalty.
Planning Across Markets
The 2026 calendar creates three near-simultaneous compliance obligations for businesses with global chemical supply chains: the TSCA PFAS reporting window, the K-REACH SDS format change, and the first UK REACH registration deadline. Businesses active in all three markets face a compressed timeline for completing substance inventories, updating hazard communication documents, and building or confirming registration dossiers — often drawing on the same internal compliance resources.
A phased internal programme should prioritise the TSCA PFAS reporting preparation (Q4 2025 to Q1 2026 substance identification), the K-REACH SDS audit and update (Q1–Q2 2026), and UK REACH registration dossier completion (Q1–Q2 2026 for Phase 1 substances). The EU REACH 2.0 and EU PFAS restriction processes require monitoring and scenario planning rather than immediate action, but building PFAS alternative assessment programmes now avoids the worst of the timeline pressure when formal restriction deadlines are set.
Deadline approaching?
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