Global Industrials bulletin - November 2025

In our latest update we highlight key areas of change that have happened over the last quarter. These include:

• Asia
• Europe
• UK
• US

Asia

China: Further restrictions on rare earth mineral exports announced

Summary: On October 9, the Ministry of Commerce announced that export controls on rare earth and other items will be increased. The new rules place controls on 13 rare earth-related products (Rare Earth Elements), including:

• individual metals: samarium, dysprosium, gadolinium, terbium, lutetium, scandium, and yttrium
• alloys: samarium–cobalt, terbium–iron, dysprosium–iron, and terbium–dysprosium–iron
• oxides: dysprosium oxide and terbium oxide
• In addition, the rules also cover certain intermediate products (Intermediate Products) in the rare earth industry chain, including rare earth permanent magnet materials and rare earth target materials. These items, along with the 13 Rare Earth Elements, are collectively referred to as the “Listed Elements”. These Listed Elements are used in various sectors, including the manufacture of medical devices, scientific instruments, lithium batteries and electronics.

Impact: Effective December 1, 2025, the new rules require foreign organizations and individuals to obtain a dual-use item export license from the Ministry of Commerce before exporting certain specified items to countries or regions other than China, including:

• Intermediate Products manufactured outside of China that contain, integrate, or are mixed with Chinese-origin Rare Earth Elements, where the value of those elements accounts for 0.1% or more of the total item value; or
• Listed Elements produced or manufactured outside of China using technologies related to Chinese-origin rare earth extraction, smelting and separation, metal smelting, magnetic material manufacturing, or secondary resource recycling

Separately, the requirement to obtain a license for the export of Listed Elements produced or manufactured in China took effect immediately upon the promulgation of the rules on October 9, 2025.

Businesses would benefit from reviewing their exposure to the new rules now and applying for required licenses ahead of the effective dates.

China: New export rules for electric passenger vehicles

Summary: On September 26, China’s Ministry of Commerce , along with three other authorities, announced that new export license requirements for Chinese car manufacturers will apply from January 1, 2026. The new rules align requirements for electric cars with existing requirements for conventional cars and motorcycles, introduced in 2012.

Impact: The policy aims to support good trade relationships, with the rules setting minimum standards for after-sales support. Businesses should prepare for increased scrutiny of export license applications, with potential for longer processing times.

China: Lithium battery standard released

Summary: On August 11, the State Administration for Market Administration announced the approval of a new standard (GB/T 45915-2025) for the safe transportation of lithium batteries. The new national standard outlines classification, packaging, handling, storage, multi-modal transport, and emergency response requirements. It builds on United Nations guidelines and introduces a new grading system for lithium battery transport. Packaging standards for used and waste batteries are also addressed, and document and information-sharing protocols clarified.

Impact: The new standard will take effect on February 1, 2026. Manufacturers and distributors of lithium batteries should take note of new requirements and take steps to ensure they are in compliance.

China: New guidelines for strengthening financial support for industrialization issued

Summary: On August 5, 2025, the People’s Bank of China and six other authorities published guidelines to strengthen financial support for new industrialization. The stated aim is to establish a financial system tailored to support the development of the advanced manufacturing sector by 2027. Support measures focus on industry innovation, developing modern industry systems, balanced regional growth, and improving financial institutions. The guidelines call for optimized financial tools to support emerging industries such as connected vehicles, semiconductors and advanced manufacturing. Upgrading of traditional industries, and financing of supply chains is also addressed.

Impact: Critical and emerging industries may benefit, as measures are introduced to encourage and accelerate investment. Businesses in traditional industries may be able to access increased financial support for their efforts towards digitalization and more sustainable operations.

The guidelines reflect a focus on support for sustainable development in advanced industries and innovative technologies.

China: Battery technology export restrictions amended

Summary: On July 15, the Ministry of Commerce and the Ministry of Science and Technology updated the Catalogue of Technologies Subject to Export Prohibitions and Restrictions. Now included are key technologies related to:

• battery cathode materials, including lithium iron phosphate (LFP)
• lithium extraction and processing
• Non-ferrous metal smelting and rolling technologies, including gallium extraction technologies

These technologies are critical to the clean energy, electric vehicle (EV), and semiconductor industries. LFP cathode materials technology is central to the production of cost-effective and high performance EV batteries. Gallium extraction technologies are used to produce critical material used in semiconductors.

The stated aim is to balance technological development with national economic security.

Impact: Starting from July 15, 2025, manufacturers exporting these technologies will be required to obtain a government license. Businesses involved in joint ventures, or participating in licensing or technical services agreements, may also need to secure licenses. Gaining approval for exporting restricted technologies may be a lengthy process, with applications potentially subject to multiple reviews. Businesses should submit license applications promptly if needed, to prevent operational delays.

Europe

EU: New Defense Roadmap presented

Summary: On October 16, the European Commission presented the ‘Defense Readiness Roadmap 2030’. It aims to strengthen EU defense capabilities and close critical gaps through joint development and procurement across Member States.

Four European Flagships are proposed: Drone Defense Initiative, Eastern Flank Watch, Air Shield, and Space Shield. The roadmap promotes Capability Coalitions in nine areas, including cyber, AI, mobility, and missile systems. It aims to support a resilient EU defense industry, tapping innovation and reducing supply chain dependencies. A harmonized EU defense equipment market is planned to scale production and boost investment. It includes a military mobility area by 2027 to ensure swift troop and equipment movement. The roadmap builds on the ReArm Europe Plan.

Impact: Businesses may benefit from increased EU defense spending and joint procurement. They may access new markets through Capability Coalitions and integration of Ukraine’s defense industry.

Defense businesses may see rising demand for military equipment, cyber tools, AI systems, and space technologies. Logistics and dual-use technology providers may play expanded roles in military mobility.

EU: Strategic projects to boost raw materials security

Summary: On September 25, the European Commission (EC) launched its second call for strategic projects under the Critical Raw Materials Act. It aims to secure sustainable raw material supply for green and digital transitions, building on 60 projects from the first call. Projects must enhance supply security, be technically feasible, and ensure sustainability to qualify for fast-track permitting and financing. The initiative aims to boost domestic production, diversifies supply, and strengthens partnerships with countries outside the EU.

Impact: Businesses in raw materials, mining, and recycling sectors may benefit from faster permitting and easier access to EU funding. Strategic project status offers visibility, regulatory support, and potential partnerships across the EU and globally.

The call is open until January 15, 2026.

EU: New Standard for electric vehicle batteries

Summary: On September 16, the European Committee for Standardization (CEN) introduced a new standard to guide safe reuse of electric vehicle batteries. It aligns with the EU Battery Regulation.

The standard ensures certified workshops follow strict safety protocols for repair, reuse, and repurposing of EV batteries. It mandates full battery health checks before any operation. Traceability is reinforced through battery passports and unique identification numbers for every reused or repurposed unit. Design-for-repair principles are promoted to ease future servicing and support circular economy goals in mobility. The initiative reduces waste, boosts sustainability, and builds consumer trust in second-life battery applications.

Impact: CEN develops voluntary standards, therefore the standard will be implemented by the national CEN Members – and transposed into a national standard. Manufacturers may need to adapt designs for repairability, potentially increasing upfront costs but enabling long-term circular value.

EU: ECHA to launch consultation to shape PFAS restriction policy

Summary: On September 15, the European Chemicals Agency (ECHA) announced a spring 2026 consultation on per- and polyfluoroalkyl substances (PFAS) restriction. The draft opinion of the Committee for Socio-Economic Analysis (SEAC) will assess socio-economic impacts and alternatives to PFAS across sectors. The consultation will use a structured survey, open for 60 days to all stakeholders.

ECHA will host an online info session on October 30, to support stakeholder preparation. Final SEAC opinion is expected by end of 2026, concluding scientific evaluation of the proposal.

Impact: New restriction options could introduce new compliance and reporting requirements across multiple sectors, including health, industrials, energy and transport. Businesses should assess operational and supply chain risks linked to potential use-specific restrictions or emission controls.

EU: Parliament adopts its position on End-of-Life Vehicles Regulation

Summary: On September 9, the European Parliament (EP) adopted its position on the End-of-Life Vehicles Regulation proposal. The Regulation promotes circularity in vehicle design and end-of-life management, replacing outdated regulations. It applies to more vehicle types, including motorcycles, lorries, and buses, and covers the full vehicle life cycle.

New vehicles must allow easy removal of parts for reuse, recycling, or refurbishment by authorized facilities. Within six years, vehicles must contain at least 20% recycled plastic, improving material sustainability. Manufacturers will bear extended producer responsibility for end-of-life vehicle collection and treatment after three years. The EP calls for clearer distinctions between used and end-of-life vehicles, with export bans on the latter.

Impact: With both Council and EP positions adopted, trialogue negotiations will begin to finalize the Regulation text.

The rules will significantly impact automotive businesses. Manufacturers must redesign vehicles for easier dismantling and integrate at least 20% recycled plastic within six years, rising to 25% in ten years. Manufacturers may then have to increase their use of recycled plastic, steel and aluminum. They’ll also face extended producer responsibility, covering costs for collecting and treating end-of-life vehicles. The Regulation also introduces new compliance obligations and shifts accountability upstream in the supply chain.

EU: ECHA revises PFAS restriction proposal and announces timeline

Summary: On August 20, the European Chemicals Agency (ECHA) published an updated proposal to restrict PFAS under the EU’s REACH regulation. Authorities from five countries revised the initial 2023 proposal.

The updated Background Document now includes assessments for eight additional sectors, such as military, medical, and industrial uses. Alternative restriction options were also considered, allowing PFAS use where risks are controllable. These options may cover manufacturing, transport, electronics, energy, and textiles.

ECHA’s Risk Assessment and Socio-Economic Analysis committees (scientific committees) will produce the final opinions. These will cover 14 original sectors, PFAS manufacturing, and horizontal issues. These horizontal issues include hazard assessments and general risk management measures such as reporting and PFAS management plans.

Impact: New restriction options could introduce new compliance and reporting requirements across multiple sectors, including health, industrials, energy and transport. Businesses should assess operational and supply chain risks linked to potential use-specific restrictions or emission controls.

ECHA’s scientific committees are currently evaluating the proposal. On August 27, ECHA confirmed that its scientific committees aim to finalize their opinions by 2026. They also aim to conclude their discussions on the 14 original sectors and horizontal issues by end 2025.

The European Commission will make the final decision in consultation with Member States. The decision will be supported by the Background Document and the final opinions of the scientific committees.

EU: New chemical exposure limits to protect workers’ health

Summary: On July 18, the European Commission (EC) proposed stricter chemical exposure limits to better protect workers’ health across the EU. The sixth revision of the Carcinogens, Mutagens and Reprotoxic Substances Directive introduces new limits for cobalt, Polycyclic aromatic hydrocarbons, and 1,4-dioxane. Welding fumes are now included due to their carcinogenic risks.

This initiative supports the EU’s Strategic Framework on health and safety at work and Europe’s Beating Cancer Plan.

Impact: Transitional limits will help businesses adapt gradually. The changes are expected to save €1.16 billion in healthcare costs and improve workers’ quality of life. These measures aim to prevent 1,700 lung cancer cases and 19,000 other illnesses over 40 years. The EC proposal will be discussed by the European Parliament and Council. Once adopted, Member States will have two years to implement the rules.

EU: European Commission issues guidance for Automotive Patent Licensing Group

Summary: On July 9, the European Commission (EC) issued informal antitrust guidance to support a new Automotive Licensing Negotiation Group (ALNG). The ALNG aims to simplify licensing of standard essential patents (SEPs) for connected vehicles, including 4G and 5G technologies.

The guidance clarifies how companies can jointly negotiate standard essential patents (SEP) licenses without violating Article 101 TFEU. Participants must avoid sharing sensitive business information and must not coordinate pricing or licensing terms. The ALNG does not breach competition rules, provided it remains open, voluntary, and transparent.

This initiative is part of the Industrial Action Plan for the European Automotive Sector, boosting innovation and competitiveness.

Impact: This move contributes to the EU’s digital and green transitions by enabling smoother deployment of connected and automated vehicles. It also supports fair access to key technologies, reducing transaction costs and legal uncertainty for EU carmakers. The EC may issue further guidance as SEP licensing practices evolve.

EU: Action Plan to boost chemical industry competitiveness

Summary: On July 8, the European Commission (EC) presented an Action Plan to strengthen the EU chemical industry.

Key measures include establishing a Critical Chemical Alliance to support critical production sites. They also include implementing the Affordable Energy Action Plan to reduce energy costs. Fiscal incentives will be introduced to boost demand for clean chemicals. The Action Plan reaffirms the EC’s commitment to minimize PFAS emissions. It is supported by upcoming initiatives like the Industry Decarbonization Accelerator Act and the Bioeconomy Strategy. Additional measures include the Circular Economy Act and EU Innovation and Substitution Hubs for safer chemical alternatives.

On September 24, the Council of the EU adopted its position on the ‘stop-the-clock’ mechanism on chemicals. It would postpone to January 1, 2028, the date of entry into application of the revised regulation on classification, labeling, and packaging of chemicals (CLP regulation).

Further amendments extend deadlines for relabeling, formatting, advertising, distance sales, and fuel pump labeling requirements. They include changes to the CLP Regulation, Cosmetics Regulation and Fertilizing Products Regulation.

Impact: The sixth omnibus simplification package will ease labeling and product rules, potentially saving businesses €363 million annually. Simplified chemicals regulations could also reduce burden on industry stakeholders.

Application delay until 2028 would ease immediate pressure, but businesses should use this time to prepare for changes under the revised CLP Regulation, Cosmetics Regulation and Fertilizing Products Regulation. Harmonized dates across these three laws support long-term planning, while early preparation on labelling, packaging, and sales materials helps avoid last-minute bottlenecks.

UK

UK: Department for Environment, Food and Rural Affairs publishes UK REACH policy paper

Summary: On July 31, the Government set out its rationale for prioritizing substances under the UK REACH work program for 2025–26. The work program outlines how the Health and Safety Executive (HSE), supported by the Environment Agency, will regulate in 2025–2026. It includes restrictions and time-limited authorizations of substances; key risk management tools applied under UK REACH.

No new restriction workstreams are initiated, but emerging chemical risks will continue to be monitored. The focus remains on controlling risks from Substances of Very High Concern (SVHCs), while working towards substitution of SVHCs where feasible. Plans for an HSE consultation on the development of a UK REACH restriction on per- and polyfluoroalkyl substances (PFAS) in fire-fighting foams are announced in the plan.

Impact: The aim of the work program is to ensure a “stable, predictable and consistent approach to chemicals regulation, more aligned with our closest trading partners”. Businesses may benefit from more certainty and reduced regulatory complexity as the UK aims to align more closely with other jurisdictions.

PFAS are facing more regulation and litigation in jurisdictions such as the US and EU. This development suggests that the UK Government could consider comparable regulatory measures for these chemicals.

UK: Call for evidence on UK machinery safety regulation

Summary: On July 28, the Office for Product Safety & Standards (OPSS) opened a call for evidence on UK machinery safety regulation. The OPSS is reviewing the Supply of Machinery (Safety) Regulations 2008, which implemented the EU Machinery Directive 2006 in the UK. These Regulations set out the legal basis for permitting CE marked machinery products to be placed onto the GB market.

From January 2027, in the EU, the EU Machinery Directive 2006 will be superseded by the Machinery Regulation 2023. The OPSS is therefore considering, whether the UK’s machinery safety regime should be reformed in line with the new EU regime. This could reduce trade friction between the UK and EU due to continued GB recognition of CE marking for machinery products. It would also mean that GB market rules would be aligned with those applying to Northern Ireland, under the Windsor Framework.

Impact: The call for evidence closed on October 20, and the Government is now considering the responses. Views were sought on the following aspects of the new EU regime and their suitability for the UK: introduction of essential health and safety requirements relating to new and emerging tech; use of common specifications as a way of showing conformity; introduction of importer and distributor requirements; and introduction of third-party conformity assessments for some products. Any changes to the UK regime will be made under the Product Regulation and Metrology Act 2025. 

UK: DRIVE35 program of automotive sector investment launched

Summary: On July 13, the UK Government launched the DRIVE35 program, part of the Modern Industrial Strategy. The program commits £2.5 billion in funding for the automotive sector over the next decade. It includes £2 billion in funding up to 2030, and an additional £500 million for research and development until 2035. 

DRIVE35 comprises funding competitions planned to support a spectrum of projects from start-ups to established high-volume manufacturing and multi-billion-pound gigafactories. On July 14, the Government opened funding competitions for businesses to apply for grant funding for:

• large-scale capital investments in the manufacture of zero emission vehicles and their supply chain components
• support for detailed feasibility studies into the deployment of UK-based manufacturing facilities for zero emission vehicle technologies
• collaborative and individual business R&D projects, that design, develop and manufacture strategically important zero emission vehicle technologies

Impact: DRIVE35 aims to support UK auto manufacturers of all sizes with targeted investments in advanced automotive technologies. The committed funding is intended to encourage manufacturers to invest in sustainable supply chains and the production of zero-emission vehicles. Guidance on the funding competitions and application process can be found on the Department for Business and Trade website.

US

US: Administration announces tariffs on medium and heavy truck imports

Summary: On October 17, an Executive Order announced the intention to introduce a 25% tariff on imported medium and heavy trucks, and vehicle parts. The Order states that this will be in effect from November 1. It aims to protect the domestic industry. The Executive Order cites national security issues and a Commerce Department investigation of the sector under Section 232 of the Trade Expansion Act of 1962.

Impact: Supply chains for heavy duty vehicles are highly integrated across geographic regions. The tariffs could impact foreign manufacturers and businesses involved in the supply chain of components for these products. Potential impacts could include increased costs for original equipment manufacturers or some shifting of production to domestic sites.

US: Proposed changes to refrigerant rule

Summary: On October 3, the Environmental Protection Agency (EPA) issued a proposed rule reforming the 2023 Hydrofluorocarbon (HFC) Technology Transitions Rule. The proposed change aims to reduce costs and improve access to refrigerants for business. It would extend compliance deadlines for HFC use in air conditioning, refrigeration, and semiconductor manufacturing.

It seeks to address public concerns about refrigerant shortages and increased costs during hot weather. The new rule would allow continued installation of older systems made before January 1, 2025. It would also raise the global warming potential (GWP) threshold for cold storage warehouses, making them more generous, starting January 1, 2026.

Further potential adjustments include:

• January 1, 2027: Supermarket system compliance
• January 1, 2028: Laboratory equipment compliance
• January 1, 2030: Semiconductor equipment compliance
• January 1, 2032: GWP limits for retail food systems

Impact: The proposed rule could impact manufacturers and businesses using air conditioning, refrigeration, and semiconductor products. The EPA is taking comments on the proposed changes until November 17. Businesses should consider submitting their views to ensure they are taken into account. If implemented, extended deadlines outlined in the rule could benefit businesses, giving them more time to prepare for any product specification changes.

US: Revision of existing chemicals risk evaluation process

Summary: On September 23, the Environmental Protection Agency (EPA) proposed a revised risk evaluation framework for chemicals already in the marketplace. Under the Toxic Substances Control Act (TSCA), risk evaluations determine the risk a substance presents to health or the environment. The EPA’s proposed rule includes targeted revisions intended to improve transparency and efficiency. Key changes include:

• separate risk determinations for each condition of use, rather than a single overall assessment
• clearer guidance on how occupational exposure controls (e.g. PPE, industrial systems) are considered
• defined scope for which uses, exposure routes, and pathways EPA will evaluate
• updated definitions intended to enhance transparency
• streamlined procedures for revising or supplementing evaluations to meet statutory deadlines
• adjusted requirements for manufacturers requesting EPA-conducted evaluations

Impact: The proposed changes seek to make the regulatory process more predictable for chemical substance manufacturers and importers. Less information may be required for each risk evaluation. However, businesses could be subject to more targeted evaluations. Affected businesses should consider reviewing their current operations to ensure they are prepared for the new documentation requirements.

US: New chemicals used for data center projects to be prioritized

Summary: On September 18, the Environmental Protection Agency (EPA) announced prioritization of certain chemical reviews required under the Toxic Substances Control Act. The focus is on chemicals used in data center projects, or in the manufacture of specific components. The announcement follows the Executive Order ‘Accelerating Federal Permitting of Data Center Infrastructure’, signed on July 23. Under the Executive Order, the EPA is directed to expedite permitting on federal and non-federal lands for qualifying AI-related projects.

To qualify for prioritized review, businesses must submit a cover letter identifying the chemical’s intended use and associated data center. The prioritization of reviews will start with submissions received from September 29.

Impact: The EPA’s stated goal is to reduce the regulatory burden on businesses seeking to invest in these types of chemicals. Chemical manufacturers can also request a priority review of a new chemical if it’s intended use is in data center infrastructure.

US: 407 product categories added to steel and aluminum tariffs

Summary: On August 19, the Department of Commerce announced an additional list of products to be covered by tariffs. The steel and aluminum content of these products will now be subject to a 50% duty rate. Among the 407 additional product categories now included are:

• wind turbines and their parts and components
• mobile cranes
• bulldozers and other heavy equipment
• railcars
• furniture
• compressors and pumps

The latest inclusions have notably expanded the scope covered. The affected product list now encompasses industrial and chemical products, as well as consumer and personal care goods.

There are three annual periods for public steel and aluminum product inclusion requests. The next opportunity opens in January 2026.

Impact: The 50% duty on steel and aluminum content could significantly impact costs and supply chains. Businesses should review the full list of affected product categories and evaluate their sourcing strategies and pricing models if required. Importers will need to comply with new requirements, including verifying the origin and processing of affected products. Businesses may also consider preparing submissions for any products they believe should be excluded in future inclusions request windows.

US: New tariffs on copper imports announced

Summary: On July 30, the Administration announced increased tariffs of 50% on imported copper products. The increased rate applies from August 1, 2025, and applies to semi-finished copper products, including copper pipes, wires, rods and sheets. It also applies to copper-intensive derivative goods, such as cables and electrical components. The new rate does not apply to raw forms of copper, anode and cathode material or copper scrap.

The proclamation also directs the Secretary of Commerce to take steps to boost the US domestic copper industry. This includes a requirement that 25% of high-quality copper scrap produced in the US must be sold in the US. Additionally, from 2027, 25% of copper input materials produced in the US will be required to be sold domestically. The requirement will rise to 30% in 2028 and 40% in 2029. Copper input materials include products such as copper ores, concentrates, mattes, cathodes, and anodes.

Impact: Businesses importing affected copper products may experience price increases and disruption to their supply chains. Electric vehicle manufacturers, defense, electronics and AI industries could be particularly affected. The housebuilding sector may also be impacted, with tariffs potentially leading to increased construction costs.

US: Environmental Protection Agency proposes rescinding greenhouse gas endangerment finding

Summary: On July 29, the Environmental Protection Agency (EPA) proposed rescinding the legal basis for regulating greenhouse gas (GHG) emissions under the Clean Air Act. This move, if finalized, could eliminate the legal basis for certain regulations under the Clean Air Act that address GHGs from vehicles, power plants, and industrial sources. It could lead to the dismantling of climate policies including vehicle emissions standards and Biden-era electric vehicle targets.

Impact: If implemented, the rule would remove requirements concerning emission standards, testing procedures and reporting requirements. Vehicle and engine manufacturers should be prepared for a period of uncertainty, as the proposal is likely to face legal challenges and public scrutiny.

US: Regulatory exemptions for chemical manufacturers, coal-fired power plants

Summary: On July 17, the Administration issued a series of proclamations concerning certain stationary sources deemed to be critical to national security. These include certain chemical manufacturers involved in the production of semiconductors and medical device sterilizers, iron ore processing facilities and coal-fired power plants. The proclamations permit facilities to follow earlier Environmental Protection Agency (EPA) standards instead of stricter rules implemented by the Biden administration.

Impact: Facilities listed in the proclamations will have a two-year exemption from compliance with several EPA standards. The proclamations align with the EPA's March 2025 announcement of a major environmental deregulation program.

Further reading

Navigating EU Law | Strategic Guidance for a Shifting Regulatory Landscape | Business Topic

Global Sustainability & ESG Insights - August & September 2025 | Eversheds Sutherland

Global Supply Chain Horizons – September 2025

Beyond PFAS: A new wave of endocrine disruptor litigation

EU 2028 – 2034 Budget Proposal: Business Implications

UK's Modern Industrial Strategy aims to boost chemicals sector via energy savings and regulatory reforms

Co-authored by Claire Webb, Paola Paccani and Westley Trimble (Knowledge)