July 2025: Global Industrial Bulletin
Key Updates and Insights
2025. gada 01. jūlijs
July 2025: Global Industrial BulletinKey Updates and Insights2025. gada 01. jūlijs We're delighted to share our Knowledge team's insights on the most important legal changes affecting the Industrials sector around the globe In this edition of our global AI bulletin, we will be looking at: Global180 countries adopt decisions on management of chemicals and wastes.On May 9, the 2025 meetings of the Conferences of the Parties to the Basel, Rotterdam, and Stockholm Conventions concluded. Governments of 180 countries adopted agreements relating to managing chemicals and waste, human health, environment protection, and climate change. Key decisions include the elimination of three persistent organic pollutants:
Additionally, guidelines for managing UV-328 waste were agreed. This is a persistent chemical used in plastics and various industries to prevent UV degradation. Impact: The agreed changes aim to promote transparency in the trade of hazardous chemicals. If implemented, the new amendments will require businesses to comply with stricter regulations on hazardous chemicals and waste. Asia
South Korea: Plan on circular use of batteries announcedOn May 14, the Ministry of the Environment (MoE) announced a plan to revitalize the circular use of batteries. The goals include introducing a certification system for valuable metals from waste batteries. Measures include:
Impact: The MoE intends to prepare a legal basis for the certification system. It will promote the enactment of relevant laws and establish a Battery Resource Circulation Cluster by late 2025.
China: New export controls on rare earth materialsOn April 4, the Government announced new export controls on specific medium and heavy rare earth materials. These prohibit the export of seven types of rare earth materials: samarium, gadolinium, terbium, dysprosium, lutetium, scandium and yttrium. The new controls also apply to oxides, alloys, compounds and mixtures using these materials. Impact: All export of these materials is now prohibited without a valid license. The new restrictions increase potential for disruption to global manufacturing businesses. The automotive sector is particularly affected, as the materials are essential in the manufacture of combustion engine and electric vehicles. EU
EU: European Commission consults and readies WTO tariff responseThe European Commission (EC) launched a consultation on potential countermeasures against US tariffs. This consultation covers US imports worth €95 billion. It also includes possible restrictions on EU exports of steel scrap and chemical products worth €4.4 billion. The EC will also launch a WTO dispute against the US tariffs targeting ‘reciprocal’ tariffs on cars and car parts. This involves formally lodging a request for consultations. Impact: The consultation closed on June 10. The EC will now finalize its proposal and consult Member States. Businesses importing targeted products are likely to face increased costs and disruption is possible across their supply chains.
EU: Council amends CO2 standards for vehicle manufacturersOn May 27, the European Council adopted an amendment to the regulation on CO2 standards for new passenger cars and vans. This will modify compliance assessment methods for vehicle manufacturers. The amendment introduces a three-year averaging period for emissions targets covering 2025-2027, replacing the current annual assessment system. Impact: The new rules address concerns raised by manufacturers, offering greater flexibility in achieving CO2 emission targets. They continue to adhere to the EU’s climate ambitions. By permitting pooling agreements to be communicated by the end of 2027, manufacturers can better manage strategies. This allows for reduced compliance costs. Averaging emissions performance across 2025-2027 will allow a more balanced approach to meeting targets. The rules account for fluctuations in production and innovation cycles. Setting out longer-term compliance periods provides manufacturers with more certainty. This could encourage investment in cleaner technologies and sustainable practices.
EU: Selection criteria for net-zero strategic projects adoptedOn May 23, the European Commission adopted secondary legislation under the Net-Zero Industry Act (NZIA). The NZIA was created to help scale up the EU’s manufacturing capacity for net-zero technologies. Impact: EU-located projects contributing to the NZIA objectives, and meeting certain criteria, may qualify as 'net-zero strategic projects'. This will allow them to receive specific benefits such as faster permitting procedures. Read more on the selection criteria in our briefing
EU: European Chemicals Agency proposes restrictions on chromium (VI) substancesOn April 29, the European Chemicals Agency (ECHA) proposed an EU-wide restriction on certain hexavalent chromium (Cr(VI)) substances. The aim is to protect workers and the public from their carcinogenic effects. Chromium (VI) is used in various industries, including electroplating, stainless steel production, textile manufacturing, and the manufacture of pigments and paints. The ECHA proposal targets specific uses, including electroplating and surface treatments, while allowing limited exceptions. It also includes barium chromate in the scope of the restriction to avoid it being used as a substitute. Impact: If enacted, the new restrictions could result in operational disruptions. Businesses may consider focusing on investment in alternative materials. There may also be additional reporting and compliance costs involved in meeting new regulatory requirements. Stakeholders will have the opportunity to provide evidence-based information during the six-month consultation, started on 18 June 2025. The ECHA will evaluate the restriction proposal, considering evidence received during the consultations. The European Commission, and EU Member States, will then decide on the restriction and its conditions. EU: European Chemicals Agency publishes detail of microplastics reporting requirementsOn April 16, the European Chemicals Agency (ECHA) published REACH restriction reporting requirements on microplastics, and the timeline for implementation. The REACH Regulation's microplastics restriction mandates annual reporting of synthetic polymer microparticles (SPM) emissions by manufacturers, industrial users, and suppliers. Reporting aims to monitor the effectiveness of use and disposal instructions and improve risk management. SPM are defined as solid polymers in particles or coatings, with specific size criteria. Exemptions include industrial uses, medicinal products, food additives, and diagnostic devices. Impact: Businesses that produce or use synthetic polymer microparticles must comply with new reporting requirements, unless included in the listed exemptions. SPM suppliers will also be required to report. The first reporting deadline is 31 May 2026. It applies to manufacturers and industrial downstream users of SPM in the form of pellets, flakes, and powders. Businesses involved in other uses will be required to report from 2027. Affected businesses should review the new requirements, assess their current operations, and have effective data collection and reporting processes in place. Failing to meet the reporting requirements could incur enforcement actions by Member States, such as fines and other penalties. EU: European Parliament adopts position on streamlining chemical safety assessmentsOn April 1, the European Parliament (EP) adopted its position on the ‘one substance, one assessment’ package to streamline chemical safety assessments. The proposals aim to improve availability and access to data by establishing a common data platform for information relating to chemicals. Additionally, the proposed changes would re-allocate responsibilities for chemicals assessments between EU agencies, streamlining regulatory actions. The reforms are part of the current 2020 EU Chemicals Strategy for Sustainability. The European Commission also announced its intention to launch a chemicals industry package, and targeted revision of REACH during 2025. Impact: Simplified chemicals regulations could reduce burdens on industry stakeholders, as well as increasing consistency and predictability in decision-making processes. EU: Strategic Projects supporting critical materials value chainOn March 25, the European Commission (EC) announced a list of 47 Strategic Projects across 13 EU Member States. The step marks an implementation milestone for the Critical Raw Materials Act (CRMA), which came into force in May 2024. The aim is to strengthen and diversify the raw materials value chain within the EU, ensuring 2030 targets can be met. Each project covers at least one segment of the raw materials value chain. They include 14 of the 17 strategic raw materials listed in the CRMA, such as lithium, nickel, cobalt, manganese, graphite, magnesium, and tungsten. Requiring a capital investment of €22.5 billion, these projects will receive support from EU institutions, and benefit from a streamlined permitting process. The permit-granting process will be limited to 27 months for extraction projects and 15 months for others. This represents a significant difference to the current 5-10 year process. Impact: The projects aim to promote growth in various sectors, including aerospace, defense, clean energy and modern technologies. The EC expects these projects to drive investment and innovation in domestic raw material production, and extraction and processing technologies. Materials used in battery manufacturing are covered by multiple projects, supporting growth in the European automotive industry. The EC plans to open a second call for Strategic Project applications in the summer. EU: European Commission tracking imports of certain industrial chemicalsOn March 24, the EC announced that it is monitoring import volumes of certain ethylene and ammonia products. These include ethylene copolymers, high-nitrogen urea and ammonium sulphate. These chemical products are used mainly in fertilizer production and industrial applications. Impact: The surveillance does not place restrictions on imports. The EC states that the surveillance is in response to a significant increase in the EU’s market share of imports. It cites trade defense measures and production overcapacity among causes of the increase in import volumes. EU: New European partnerships on advanced materials, photovoltaics and textilesOn March 20, the European Commission announced three new European Partnerships under its Horizon Europe research and innovation funding program. These partnerships aim to boost innovation in advanced materials, textiles, and photovoltaics.
The first funding opportunities under these partnerships will be part of the Horizon Europe Work Programme 2025 Impact: These partnerships aim to drive strategic research and innovation by aligning efforts, leveraging private investments, and preventing duplication. They present opportunities for businesses to benefit from new investment. The European Commission and private partners plan to invest up to €240 million each for photovoltaics from 2025-2030. Investments of €30 million each for textiles, and €250 million each for advanced materials are also planned. EU: New regulation on food contact plasticsOn March 16, Commission Regulation (EU) 2025/351 entered into force. It introduces amendments to Regulation (EU) 10/2011 on plastic food contact materials (FCMs). It also makes minor updates to Regulation (EU) 2022/1616 on recycled plastics FCMs and Regulation (EC) 2023/2006 on good manufacturing practice of FCMs and FCAs. The regulation broadens the scope of compliance to include adhesives, coatings, and printing inks. It introduces stricter purity standards for non-intentionally added substances, and mandates new labelling requirements for repeated use articles. It also specifies testing procedures for migration in multi-layer articles and updates recycling facility requirements. Transitional measures for compliance run until September 16, 2026 Impact: The regulation will impact food and beverage manufacturers, packaging producers, plastics manufacturers and recyclers. Businesses should use the transition period up to 2026 to review materials and adapt any product migration protocols. They may also be required to upgrade recycling systems to meet new standards. Any business that manufactures plastic FCMs designed for repeated use should ensure products comply with new labelling requirements. EU: Action Plan for the automotive sector publishedOn 5 March, the EU published its Action Plan for the automotive sector. It builds on the Strategic Dialogue on the Future of the European Automotive Industry, launched in January. By introducing new measures, the EU aims to boost demand for electric vehicles (EVs). It includes measures to help EU manufacturers to electrify their fleets, and ensure their competitiveness in the EV market. Impact: The Action Plan proposes new EU requirements and conditions that may affect businesses’ supply chains. Find out more in our Flash Update EU: European Commission updates battery-related waste codesOn March 5, the EC updated the List of European Waste to include new battery-related waste codes. Shredded battery waste, known as “black mass”, is a crucial material used in electric vehicle battery recycling. Black mass will now be categorized as hazardous waste. It will be subject to greater controls and kept in the European economy. The change supports the security of supply goal of the EU Battery Regulation. Among the updates, specific waste codes now cover lithium-based batteries. Black mass, nickel-based, and zinc-based waste batteries, and sodium sulfur and alkaline waste batteries are also all now classed as hazardous. Impact: This development represents a significant shift in the EU’s approach to battery waste and recycling. It limits exports to non-OECD countries and promotes recycling operations within the EU. The aim is to enhance environmental protection and supply chain resilience. The new requirements will apply from September 2026. This allows businesses a transition period, to adapt to the more stringent measures and prepare for cost implications. EU: European Commission consults on antitrust rules for automotive sectorOn 28 February, the EC launched a public consultation (now closed) on competition rules applicable to vertical agreements in the automotive sector. This consultation is part of a current process evaluating the Motor Vehicle Block Exemption Regulation (MVBER) and the Supplementary Guidelines. Both are due to expire on 31 May 2028. In addition to the public consultation, the EC will seek feedback from national competition authorities. It is also working together with its Joint Research Centre on a study focused on the digital transformation of the automotive markets, among other industry indicators. Impact: A policy-making phase on the future of the MVBER is planned for 2026, following the EC’s analysis of the evaluation. Interested parties can follow the progress of the evaluation on the EC’s ‘Have your say portal’. UK
UK: Modern Industrial Strategy 2025 publishedOn 23 June, the UK Government published its Modern Industrial Strategy 2025. The new Strategy is the first comprehensive UK-wide industrial policy since 2017. It sets out a 10-year plan aiming to increase business investment and grow the UK’s industries of the future. Eight sectors are identified as having the highest potential for growth, including advanced manufacturing, clean energy and digital technologies. Each sector has its own 10 year plan to promote growth and investment. Up to £2.8 billion of investment in R&D programs is planned for the advanced manufacturing sector. In the clean energy sector the Government plans to at least double current levels of investment by 2035. The Strategy also includes plans to prioritize frontier technologies including advanced connectivity, quantum technologies and semiconductors. Impact: A key goal of the Strategy is to reduce electricity costs for energy-intensive manufacturers by up to 25% from 2027. Eligible businesses will be exempt from certain extra charges that currently support green energy supply systems. Full details of the exemptions and eligible businesses will be decided following a two-year consultation period. The automotive industry, including connected, zero emission and self-driving vehicles, is a priority in the Advanced Manufacturing sector plan. In addition to lowering electricity costs, plans to support growth include R&D funding for vehicle-to-grid technology and capital funding for gigafactories. Government investment of £452 million is planned for the battery sector, to support innovation, recycling and enhance supply chain resilience. The aerospace industry will benefit from a planned £2.3 billion for R&D to 2035. The focus is on sustainable aviation fuel and advanced air mobility, and aimed at driving technological advancements. UK: Government opens consultation on automated vehicles marketing termsOn June 10, the Government opened a consultation on protecting marketing terms for self-driving vehicles under the Automated Vehicles Act 2024. It proposes two new marketing offences: "protected terms" and "confusion". The consultation aims to prevent misleading marketing that could endanger road safety and undermine trust in self-driving technology. It outlines which terms should be protected and how the protections would work in practice. The consultation is published alongside a call for evidence on the statement of safety principles. These represent the first part of a wider program of legislation to implement the 2024 act. The Government is targeting full implementation of the regulatory framework by the second half of 2027. Impact: Stakeholders have until 1 September 2025 to respond to the consultation. The questions cover topics including the terms to be protected, practical implications and potential costs to business. Businesses will need to ensure that they comply with the new rules as they come into force. UK: Government publishes Strategic Defence ReviewOn June 2, the UK Government published its Strategic Defence Review, making 62 recommendations across a wide range of areas. The review includes a plan to transform the UK’s defense capabilities, by increasing spending on defense to 2.5% of GDP. And up to 3% in the next Parliament. Impact: If fully implemented the plans outlined in the Review will have profound implications for all defense industries. Read more about the impact in our briefing. UK: Department for Transport outlines changes to the Vehicle Emissions Trading SchemesOn April 7, the Department for Transport published the response to its consultation on ‘Phasing out the sales of new petrol and diesel cars from 2030 and supporting the zero emission vehicle (ZEV) transition’. The response confirms the Government’s ban on the sale of new petrol and diesel cars by 2030. It also reaffirms the commitment that all new cars and vans must be fully zero emission by 2035. Key announcements include:
Impact: The changes give manufacturers greater flexibility to accelerate development and production of ZEVs to meet 2030 and 2025 targets. Reduced non-compliance payments will also ease the financial burden. Small and micro volume manufacturers, as well as special purpose vehicles, will benefit from more time to adapt. UK: New UK REACH fees and charges in effect from 1 April 2025On March 10, the Government published new regulations implementing changes to fees for registration and authorization of substances under UK REACH. Key changes include:
Discounts will continue to apply for small and medium-sized enterprises. Impact: While costs will increase for low tonnage registrations, fees applying to higher tonnage registrations have been reduced. Importers of substances or mixtures governed by UK REACH should review the amended fee structure, and adapt their budgets and processes. US
US: Environmental Protection Agency issues new rules for over 30 chemicalsOn June 13, the Environmental Protection Agency (EPA) issued Significant New Use Rules for over 30 chemical substances. These rules aim to ensure that new uses of chemical substances are assessed for potential risks before they commence. The chemicals include substances used in petroleum refineries, semiconductor manufacturing, mining, and manufacture of plastics and polymers, among other uses. Impact: The rules require manufacturers or processors to notify the EPA at least 90 days before starting any activity designated as a significant new use. The EPA will then evaluate the conditions of that use and make a determination. The rule is effective from August 12, 2025, and applies to the listed substances. The notification process includes submitting a Significant New Use Notice and may involve costs for preparation and submission, including user fees. The rule also outlines specific requirements for workplace protection, hazard communication, industrial activities, and recordkeeping. US: Defense contracts may be reviewed by Department of Government EfficiencyOn May 28, the Defense Secretary authorized the Department of Government Efficiency (DOGE) to review new contracts and ongoing procurement. Initially the authority applies to communications and utilities contracts, advisory and assistance services and professional support services. Contract awards under $1 million, requirements packages for overseas contingency operations, and contracts with performance outside the U.S. are excluded. Impact: It is not confirmed whether DOGE has authority to cancel or amend awards. However, this order adds an additional step, potentially increasing the duration of the procurement process. US: Data reporting schedule for PFAS updatedOn May 13, the Environmental Protection Agency (EPA) amended the PFAS reporting required under the Toxic Substances Control Act (TSCA). The EPA is changing the data submissions periods to ensure adequate time for developing and testing the reporting application. The aim is to facilitate compliance and minimize technical issues. The rule concerns businesses involved in the manufacture or import of PFAS. It may particularly affect construction, manufacturing, wholesale trade, retail trade, and waste management and remediation services. Impact: Businesses that have manufactured or imported PFAS from 2011 to 2022 must report data to the EPA. This includes data on exposure and environmental and health effects. The data submission period begins on April 13, 2026, and ends on October 13, 2026. For small manufacturers reporting only as article importers, the end date is April 13, 2027. Affected businesses should take steps to familiarize themselves with the reporting requirements and develop a data collection plan. This should include information on chemical identity, production, use, by-products, exposure, disposal, and health and environmental effects. US: Global automotive tariffs, and increased rates on steel and aluminum imposedThe Trump administration has increased tariffs on imported automobiles and auto parts. Effective from April 3, 2025, automobiles from all countries will be subject to a 25% tariff. Automobiles under the USMCA will face a 25% tariff on non-US content. The 25% tariff on auto parts is effective from May 3, 2025. Existing tariffs on imported steel and aluminum doubled from 25% to 50% on June 4, 2025. Imports from the UK were excluded from the new rate under the US-UK Economic Prosperity Deal. A 25% rate will apply until at least July 9, 2025. On June 12, the United States Department of Commerce announced new procedures for tariff offsets. US manufacturers can apply for offsets on imported automobile parts based on their production volume in the United States. Impact: The higher tariffs may lead to increased costs. Businesses may experience supply chain disruptions as manufacturers adjust, and may seek to source more components domestically. For more insight on the range of “Liberation Day” tariffs, see our briefing US: Steel and aluminum inclusions process launchedOn April 30, the Department of Commerce issued a rule updating the tariff inclusion process for derivative aluminum and steel products. These products, containing significant amounts of aluminum or steel, are subject to additional tariffs based on their metallic content. Examples include certain machinery, tools, and other manufactured goods. The new rule details the submission, review, and decision phases for inclusion requests. This process includes specific submission windows, valid request requirements, and a public comment period. The stated aim of this regulation is to ensure that import levels do not harm the domestic steel and aluminum industries. Impact: Businesses can now submit inclusion requests during three two-week submission periods during each year, in May, September and January. Import costs may increase on additional derivative products added to the scope of current steel and aluminum tariffs. For domestic manufacturers, the new rule may encourage investment in production capabilities, and offer potential to increase their market share. US: Environmental Protection Agency announces upcoming actions on PFASOn April 28, the US Environmental Protection Agency (EPA) announced upcoming actions concerning PFAS. The new actions will include:
The announcement signals that this will be the first step in a larger program of actions on PFAS. Impact: In anticipation of new requirements, businesses should assess their PFAS usage and emissions and prepare for potential regulatory change. Establishing robust systems for compliance with current requirements will mean chemical producers are better prepared to adapt to changing regulation. They may also consider focusing on alternatives to PFAS and identifying ways to reduce reliance on these substances. US: President Trump signs executive order to revive US shipbuilding industryOn April 9, President Trump issued an executive order aimed at addressing a decline in shipbuilding in the United States. Included in the list of key actions outlined are:
Impact: Use of Defense Production Act authorities and encouragement of private capital investment could create new opportunities in the sector. However, proposed tariffs may lead to increased costs. Businesses may consider adjusting their supply chains or investing in domestic alternatives. Proposed new regulations and fees, such as a new harbor maintenance fee, could affect operational costs. For more insight on Trump Administration executive orders, see our EO tracker US: New Mexico enacts ban on PFAS in food packaging and cookwareNew Mexico's Per- and Poly-fluoroalkyl Substances Protection Act was signed on April 8, 2025. It bans intentionally added PFAS in cookware and food packaging. New Mexico joins a list of other states, including Washington, Maine and Minnesota, enacting similar cookware bans. This has raised debate on the affordability of cookware against the importance of health and safety in relation to PFAS. The issue of PFAS has been on the Environmental Protection Agency's radar for some time. On April 28, it outlined plans including the designation of an agency lead for PFAS. Impact: The ban starts January 1, 2027, and extends to all products by 2032, with exemptions for unavoidable uses and fluoropolymers. Manufacturers should review and eliminate PFAS from products, and prepare to report PFAS use by January 1, 2027. They will be required to detail product descriptions, PFAS amounts, and manufacturer information. US: Trichloroethylene (TCE) workplace rule in force amid legal uncertaintyThe US Environment Protection Agency's (EPA) final rule to regulate trichloroethylene (TCE) took effect on March 28, 2025. The rule broadly prohibits TCE use, with certain exemptions. TCE is used in many industrial, commercial, and consumer products. These include industrial cleaners, degreasers, lubricants, adhesives, sealants, paints, coatings, automotive care products, and furniture care. Some uses of TCE were due to continue for up to 10 years, under exemptions mainly for security or national economic reasons. Section 6(g) of the Rule outlines the exemptions in detail. Due to legal challenges, the start date of these exemptions has been postponed until June 20, 2025. Impact: Businesses using TCE in any products should ensure compliance with the timeframes in the Rule. They should take note of exemptions in Section 6(g). Businesses should ensure they meet exposure limits and monitor legal developments affecting TCE regulations. US: Extended deadline for reporting on 16 chemical substancesOn March 13, the Environmental Protection Agency (EPA) extended the reporting deadline for certain substances under the Toxic Substances Control Act (TSCA). The TSCA requires manufacturers (including importers) of 16 specified chemical substances to report certain information to the EPA. The extended rules apply to vinyl chloride (extended to 11 June 2025) and 15 other substances (extended to 9 September 2025). Vinyl chloride is primarily used to produce polyvinyl chloride (PVC). Uses include: the manufacture of pipes and fittings and other construction materials, medical devices, electrical insulation, consumer goods and packaging. The 15 other chemicals affected include substances used in the production of polyurethane and plastics, manufacturing of detergents and cleaning products, perfumes and flavoring agents, dyes and industrial chemicals, pharmaceuticals, refrigerants, insecticides and pesticides, among other uses. Impact: Chemical manufacturers or importers may be affected if they manufacture or import any of the listed substances. Businesses that have manufactured, imported or produced these substances (including as a byproduct) within the last 10 years may also be affected. Affected businesses now have more time to adapt to regulatory requirements. The rules for vinyl chloride are extended to 11 June 2025, and rules on 15 other substances are extended to 9 September 2025. Further reading:
Co-authored by Claire Webb and Paola Paccani in Knowledge Jaunākais ziņas
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