Compliance Day 2026 in Padova: Key Regulatory Trends and Insights

This blog was originally posted on 9th October, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

Authored by Emilia Assenza, Manager – Global Regulatory Compliance, and Valentina Marchetti, Senior Regulatory Compliance Specialist & Team Lead, Adherent

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On 30 September 2026, industry experts gathered in Padova for the third edition of Compliance Day, organized by Analytical Group. Adherent joined the speaker panel alongside leading experts in product compliance, addressing the latest regulatory developments and the challenges they present for the fashion and consumer goods industries, as well as providing an overview of recent litigation and enforcement trends.

The event focused on four key areas:

• Regulatory Radar: Emerging Challenges for ECGT and PFAS
• Compliance outside the EU: from general rules to product impact
• Legal risks associated with non-compliance within EU regulations
• PPWR: from legislation to implementation

Designed as an interactive discussion, the event explored some of the most pressing compliance questions facing fashion companies today. This blog provides an overview of the key topics discussed across each area, together with the questions raised by the audience and the insights shared during the sessions.

Table of Contents

• Regulatory Radar: Emerging Challenges for ECGT and PFAS
• ECGT: What is the primary objective of the Empowering Consumers for the Green Transition (ECGT) directive?
• PFAS: How companies can prepare for a regulatory landscape that is still evolving
• Compliance outside the EU: from general rules to product impact
• When does compliance become legal risk?
• Packaging: The practical challenges of PPWR compliance
• Conclusion: Turning regulatory change into practical action

Regulatory Radar: Emerging Challenges for ECGT and PFAS

Adherent provided an overview of the global regulatory landscape, which is undergoing a profound transformation driven by a sharp increase in legislative output and a growing focus on sustainability, circularity and administrative simplification. 

The regulatory overview covered existing and upcoming ecodesign measures and EPR schemes for textile products, as well as key developments in digital labeling and environmental claims.

At the core of this evolution are key EU regulations, such as the Ecodesign for Sustainable Products Regulation (ESPR) and the related Digital Product Passport (DPP), with a delegated act expected in Q4 2027. These measures introduce increasingly stringent requirements around circularity and supply chain traceability, while also addressing practices such as the destruction of unsold products.

Particular attention was given to the implementation of the Empowering Consumers for the Green Transition Directive (ECGT) which regulates two different aspects:

• Amendments to Directive 2005/29/EC on Unfair Commercial Practices – Environmental Claims
• Amendments to Directive 2011/83/EU on Consumer Rights – Product Guarantees Information

Regulatory authorities across Europe and other jurisdictions are also stepping up enforcement, with companies facing increasing scrutiny and penalties for deceptive commercial practices and environmental claims that cannot be supported by objective evidence.

ECGT: What is the primary objective of the Empowering Consumers for the Green Transition (ECGT) directive?

27 September 2026 marks the start of application of the ECGT Directive. The ECGT directive aims to protect consumers from greenwashing and misleading commercial practices by updating EU rules. To that end, it modifies the Unfair Commercial Practices Directive to strictly regulate environmental claims and sustainability labels. It also amends the Consumer Rights Directive to improve transparency regarding product guarantees towards consumers.

Which specific commercial practices and environmental claims are prohibited under ECGT?

The directive bans several deceptive practices, including generic environmental claims without recognized excellence, sustainability labels lacking official certification, and claims of climate neutrality based purely on greenhouse gas offsetting. Furthermore, it prohibits presenting mandatory legal requirements as a distinctive feature of an operator’s offer.

How does the directive address product guarantees and durability for consumers?

ECGT introduces a mandatory Harmonised Notice summarising legal conformity rights (such as the two-year minimum guarantee and repair rights) and a Harmonised Label for voluntary commercial guarantees of durability exceeding two years, in order to ensure consumers receive clear, standardized information across the EU market.

Is there a transition period? Or is the ECGT Directive applicable from 27th September 2026 to existing products as well?

There is no transition period for existing products, the rules became fully applicable starting from 27 September 2026. However, to handle practical difficulties regarding existing products, the Consumer Protection Cooperation Network adopted a Common Understanding according to which national enforcement authorities may apply a flexible approach in the initial phase of application of the ECGT Directive.

PFAS: How companies can prepare for a regulatory landscape that is still evolving

Adherent concluded its session with a look at PFAS and the practical challenges companies face as the regulatory landscape continues to evolve.

PFAS have become a major regulatory focus because of their environmental persistence and the potential risks associated with this broad family of substances. In sectors such as textiles, their water-, oil- and stain-resistant properties have made them particularly useful in treatments and finishes. 

At EU level, PFAS have historically been regulated through restrictions targeting individual substances or subgroups under instruments such as POPs and REACH. This approach is still generating new restrictions: for example, the REACH restriction on PFHxA, its salts and related substances will apply to certain consumer textiles and footwear from 10 October 2026. At the same time, the regulatory direction is increasingly moving towards a broader, group-based approach, aimed at addressing PFAS more comprehensively and reducing the risk of regrettable substitution.

The proposed EU-wide PFAS restriction is a major example of this shift. The scientific evaluation progressed significantly in 2026: ECHA’s Risk Assessment Committee adopted its final opinion in March, while the Socio-Economic Analysis Committee agreed on its draft opinion in March and subsequently consulted stakeholders. As of October 2026, the final SEAC opinion has not yet been adopted and is expected by the end of the year. The EU-wide restriction has therefore not yet become a final legal requirement. If adopted, the restriction would generally apply after an 18-month transition period following its entry into force, unless a specific use is subject to a longer derogation or transition period. This makes the potential impact of the restriction an important consideration for companies already today.

At the same time, companies cannot focus only on the future EU restriction. National measures are already creating additional requirements in different Member States. France and Denmark have introduced national restrictions, while Sweden has proposed its own national measure. For companies operating across multiple markets, this creates a challenging combination of an evolving EU framework and requirements that may already differ between countries.

So how can companies prepare while the regulatory picture is still developing?

One answer is to move beyond a substance-by-substance compliance approach and look more closely at the materials, treatments and processes used in products.

Testing is an important part of this process, but the practical challenge is not simply deciding whether to test. It is understanding what to test, why to test it and which analytical approach is appropriate. A risk-based strategy can combine supplier information, material composition, manufacturing processes and targeted analytical testing to identify where PFAS may actually be relevant.

This is particularly important for textiles with water-repellent treatments or waterproof membranes. Different technologies and materials can require different analytical approaches. For example, total fluorine can be useful as a screening tool, while targeted PFAS analysis may be needed to assess the other specific regulatory limits. Understanding the treatment and material therefore helps determine what analytical evidence is actually meaningful.

The broader takeaway is that PFAS compliance is becoming a supply-chain exercise, not simply a laboratory exercise. Companies need reliable information from suppliers, visibility over where PFAS may be used and a way to connect that information to appropriate testing and technical documentation.

Compliance outside the EU: from general rules to product impact

The second session of the event, led by Analitycal Group, focused on regulatory trends affecting fashion brands in markets outside the EU, including new Chinese GB standards, Indian Quality Control Orders (QCOs) and the US CPSC eFiling requirements.

A key focus of the session was Indonesia’s halal regulatory framework, with an in-depth look at the requirements applicable to fashion companies.

Halal in Indonesia: What key factors and elements are evaluated to verify compliance and certify a product as Halal?

Halal compliance verification extends beyond the finished product and is structured around three main pillars:

• Materials: Origin, composition, animal-derived components, presence of prohibited/critical materials, and supplier documentation. Particularly sensitive components include bovine/sheep skin, animal-derived glues/adhesives, gelatin in coatings/finishes, and animal bristles in accessories.
• Process: Processing methods, substances used, risk of contact or contamination, required cleaning/separation procedures, and consistency across sites and suppliers.
• System: Traceability, documentation, appointment and responsibilities of a Halal Supervisor, and management of product/process changes.

When does Halal certification become a mandatory market access requirement in Indonesia, and what are the main steps in the certification process?

Starting 18 October 2026, Halal certification will become mandatory for affected product categories (including clothing, textiles, personal accessories, footwear, and cosmetics) to access the Indonesian market. The main steps of the certification process would include:

• Mapping: Cataloging products, SKUs, manufacturing sites, suppliers, materials, and processes.
• Preparation: Gathering Bills of Materials (BOM), technical data sheets, material origin/composition info, and facility documentation.
• Audit/Verification: Two-stage evaluation (Phase 1: document review; Phase 2: on-site audit).
• Issuance: Awarding of the Halal Certificate (valid for 1 year).
• Indonesian Registration: The local importer or representative registers the foreign certificate on the SIHALAL platform.

When does compliance become legal risk?

The discussion also explored what happens when product requirements are not met. 

What happens when a product is found to be non-compliant after it has already reached the market?

This was one of the practical questions raised during the session. 

The response can depend on how the issue is identified and which legislation applies. Where the General Product Safety Regulation (GPSR) applies and a product is found to be unsafe, businesses may need to take corrective action, including bringing the product into conformity, withdrawing it or recalling it where required. The GPSR also establishes notification obligations for businesses in relevant circumstances.

The situation is different when the issue is identified through market surveillance. Authorities can investigate products already available on the market through inspections, sampling and testing, and can require corrective measures where non-compliance is established. Depending on the circumstances and applicable legislation, these measures can include bringing products into compliance, restricting their availability, withdrawing them or recalling them, and sanctions may also apply.

For companies, one of the most important practical points is how they respond when an authority raises an issue. Market surveillance may involve authorities obtaining products from the market and testing them, making it important for companies to have the relevant technical information readily available. Technical documentation, test reports, supplier information and other evidence can help demonstrate how conformity was assessed and support a faster response.

This is particularly relevant because market surveillance does not stop at national borders. The EU’s Safety Gate system allows national authorities and the European Commission to exchange information on dangerous non-food products and corrective measures. The GPSR also provides digital channels for businesses to notify authorities and for consumers to report potentially dangerous products.

In other words, a compliance issue identified in one market may require companies to look beyond that individual product or country and assess whether the same issue could affect other products or markets.

The increasing focus on online sales adds another dimension. Online marketplaces are explicitly covered by the GPSR framework, with obligations to cooperate with market surveillance authorities and support corrective actions. At the same time, the increasing use of digital tools, including AI, is giving authorities new ways to identify and assess potentially non-compliant products, particularly across large volumes of online listings. As these tools develop, market surveillance is becoming increasingly data-driven and capable of operating at greater scale.

For companies, the practical lesson is therefore not simply “avoid fines.” It is to build a system in which non-compliance can be identified early, investigated quickly and supported by reliable evidence.

Packaging: The practical challenges of PPWR compliance

The discussion then turned to another area where regulatory requirements are creating practical challenges for companies: packaging. 

Where does the complexity of PPWR compliance lie?

Two practical challenges stand out: proving compliance and understanding who is responsible for meeting the requirements.

The PPWR brings together requirements covering areas such as chemical restrictions, recyclability, labelling and EPR. Companies therefore need to understand not only which requirements apply to their packaging, but also what evidence is needed to demonstrate conformity.

Article 5, for example, builds on existing requirements concerning substances of concern and introduces specific PFAS limits for food-contact packaging. The PPWR also links relevant information to the technical documentation required under Annex VII.

Article 6 establishes the broader requirement that packaging placed on the EU market must meet the applicable recyclability requirements. It then introduces a more detailed framework for assessing recyclability, including design for recycling criteria and recyclability performance grades, with further criteria to be established through delegated and implementing acts. Further provisions address packaging labelling and the information that must be provided to consumers and other actors.

Demonstrating compliance will therefore require more than simply stating that a packaging material is “recyclable”. Companies will need to assess the packaging against the applicable criteria and maintain the relevant information and technical documentation supporting that assessment.

The second challenge is understanding the company’s role under the PPWR. Responsibility does not necessarily sit with the company physically manufacturing the packaging.

For example, a footwear brand that has packaging designed or manufactured under its own name or trademark may qualify as the manufacturer, even if the physical packaging is produced by a supplier. The brand may also have responsibilities under the PPWR’s EPR framework, depending on how and where the packaging is made available on the market.

This has direct implications for supplier management. Companies need to establish which responsibilities remain with them, what information they need from suppliers, and which tests or technical data are required to support their own conformity assessment and EPR obligations.

Technical documentation is therefore an important part of the compliance process. It should provide a traceable link between the packaging placed on the market, its materials and components, the information received from suppliers and the company’s assessment of the applicable requirements.

This also makes supplier qualification an important starting point. Before packaging is placed on the market, companies should establish what information suppliers can provide, which requirements that information supports and where additional evidence or testing may be needed.

In practice, PPWR compliance starts well before packaging reaches the market: understand your role, identify the requirements that apply, define how compliance will be demonstrated, and establish clear responsibilities and information flows with suppliers.

Conclusion: Turning regulatory change into practical action

Compliance Day 2026 highlighted how quickly the regulatory landscape is changing for fashion and consumer goods companies. Across topics including ECGT, Green Claims, PFAS, Halal, product enforcement, and PPWR, a common question emerged: how do companies turn new requirements into practical compliance?

The discussions showed that this increasingly means preparing before a requirement becomes an immediate issue—understanding materials and suppliers, identifying responsibilities, maintaining reliable technical evidence, and using risk-based approaches to testing and assessment.

At the same time, companies operating across markets need to navigate requirements that develop at different speeds and may differ between countries, while enforcement itself is becoming increasingly digital and data-driven.

Ultimately, effective compliance is about more than keeping up with new legislation. It is about having the information, processes, and responsibilities in place to understand what a requirement means in practice, demonstrate compliance, and respond quickly when things change.

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