What’s Trending in Compliance? September 2026

Authors

Ani Nozadze

Three diverse colleagues, two men and one woman, intently looking at a laptop screen in a dark office, collaborating late at night.

This blog was originally posted on 21st September, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

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Below we break down some of the top compliance trends in September 2026 that are generating the most interest globally this month.

1. EU: Call for Evidence on Three Acts Covering Several Aspects of Packaging Relating to Article 7 of Regulation (EU) 2025/40 (PPWR), Consultation Document, August 2026

On 14 August 2026, the EU Commission published a call for evidence on two implementing acts and one delegated act on the calculation and verification of plastic recycled content, on sustainability criteria for recycling technologies, and to establish the conditions for importing plastic recyclates or articles with incorporated plastic recycled content from third (non-EU) countries.

The implementing act under Article 7(8) will cover the calculation and verification of recycled content recovered from post-consumer plastic waste recycled and collected within the European Union, and the format of the relevant technical documentation. Aspects to be considered may concern data flows, the chain of custody, the level of aggregation, evidence to be retained by operators, and independent third-party audits where needed. Economic and environmental performance, output quality, the availability of the waste, the energy needed and the emissions of greenhouse gases and other relevant environmental impacts may also be considered.

The delegated act under Article 7(9) will supplement the Regulation with sustainability criteria for plastic recycling technologies. The criteria are to be based on an assessment of available recycling technologies, considering economic and environmental performance, output quality, the availability of the waste, the energy needed and the emissions of greenhouse gases and other relevant environmental impacts.

The implementing act under Article 7(10) will establish the methodology for assessing, verifying and certifying equivalence where recycled content is recovered from post-consumer plastic waste that is collected or recycled in a third (non-EU) country. The assessment must consider protection of the environment and human health, environmentally sound recycling, high-quality recycling, resource efficiency and quality standards for recycling sectors when recycled content is collected, sorted or recycled in third countries.

According to the Commission, economic operators may incur costs for data collection, record keeping, verification, certification, audits and adaptation of information systems. These costs may affect recyclers, producers of recycled plastics, converters, packaging manufacturers, brand owners, importers, distributors, fulfilment service providers and producers placing packaged products on the EU market. SMEs may be disproportionately affected, where compliance depends on complex supply-chain data or where certification and audit costs are largely fixed and therefore less easily absorbed by smaller operators.

Importers and operators in third-country supply chains may also be affected where recycled content used in packaging placed on the EU market is linked to post-consumer plastic waste that has been collected, sorted or recycled outside the EU. The scale and distribution of these impacts will need to be examined based on specific evidence on data availability, audit and certification costs, access to recognised verification systems, certification capacity outside the EU, and possible effects on international recycled-plastic and packaging supply chains.

2. USA: 2026 Unified Agenda of Regulatory and Deregulatory Actions, Notice, 2026

On 14 August 2026, the U.S. Environmental Protection Agency (EPA) published its 2026 Unified Agenda of Regulatory and Deregulatory Actions, outlining regulatory actions that are under development, expected to be proposed or finalized, completed, withdrawn, or planned for the longer term. The Agenda covers actions under major environmental statutes, including but not limited to:

American Innovation and Manufacturing Act (AIM),
Clean Air Act (CAA),
Clean Water Act (CWA),
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or Superfund),
Emergency Planning and Community Right-to-Know Act (EPCRA),
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA),
Resource Conservation and Recovery Act (RCRA),
Safe Drinking Water Act (SDWA), and
Toxic Substances Control Act (TSCA).

Additionally, the Agenda provides projected rulemaking stages and timelines.

The Agenda does not itself establish new regulatory requirements; rather, it serves as a forward-looking regulatory planning and monitoring tool. Of particular interest, EPA identifies actions at the pre-rule, proposed rule, final rule, long-term, and completed stages, including TSCA regulatory actions for 1-bromopropane (1-BP) and N-methylpyrrolidone (NMP) at the final-rule stage. EPA is also initiating Regulatory Flexibility Act reviews of existing requirements concerning formaldehyde emissions from composite wood products, Risk Management Programs, and oil and natural gas emission standards.

Comments can be submitted until 13 October 2026.

3. UK: Deadlines for Registration and Packaging Data Reporting, Guidance Document, 2026

This newly revised guidance document aims to provide assistance in finding out when large and small producers must register for extended producer responsibility (EPR) for packaging and report data.

Deadlines for reporting packaging data depend on whether a company is a “large producer” or a “small producer” under EPR for packaging (this can be checked here), and on the year the company is reporting data for.

The guidance document provides relevant deadlines and time periods for reporting for large and small producers respectively, and also sets out information regarding resubmitting packaging data if changes need to be made (and the fees associated with resubmission).

The document also provides information on registration deadlines with some further information on registrations.

4. Canada: Requirement to Provide Information on Certain Substances under the Chemicals Management Plan, Phase 1 and Phase 2 Notices, 2026

On 29 August 2026, the Notice with respect to certain substances under the Chemicals Management Plan – 2026 Phase 1 and the Notice with respect to certain substances under the Chemicals Management Plan – 2026 Phase 2 (“the notices”) were published in the Canada Gazette, pursuant to paragraph 71(1)(b) of the Canadian Environmental Protection Act, 1999 (the Act). Phase 1 applies to 184 substances while phase 2 applies to 16 substances.

The notices aim to gather information from Canadian manufacturers, importers, and users on the commercial status, facility information (for example, releases), and uses of substances identified by the Government of Canada as priorities under the Chemicals Management Plan.

The information collected will inform further prioritization decisions, risk assessment activities and risk management actions, where required.

The reporting period for Phase 1 begins upon publication of the notice and the deadline to report is 3 March 2027. The reporting period for Phase 2 begins on 4 March 2027 and the deadline to report is 8 September 2027. The submission must be completed using the online reporting system available through Environment and Climate Change Canada’s Single Window.

5. Australia: Industrial Chemicals Categorisation, Guidelines, September 2026

Originally published in 2020, Australia’s Industrial Chemicals Categorisation Guidelines were revised in September 2026. The Guidelines assist introducers in categorising industrial chemical introductions under the Industrial Chemicals Act 2019 and must be used alongside the Industrial Chemicals (General) Rules 2019 (“IC General Rules”).

Part 2 defines technical terms used in sections 5 and 6 of the IC General Rules, including methods for calculating environment and human health categorisation volumes. Parts 3 and 4 define terms used in Chapter 2 relating to the categorisation of industrial chemical introductions. Part 5 covers terms in Chapter 4 relating to record-keeping obligations.

Part 6 defines terms in Schedule 1, including human health and environmental hazard characteristics used to determine indicative risks. It also sets out the information required to demonstrate the absence of hazard characteristics under section 30 and defines related concepts such as “suitable read across information” and “acceptable test guideline”.

Part 7 provides meanings for terms used in Schedule 2 of the IC General Rules.

The appendices provide further detail for certain definitions or concepts in the Guidelines: