EU Commission Releases New Guidelines on Identification and Tracking of Substances of Concern in Products

On November 21, 2025, the EU's Joint Research Centre (JRC) published the new report Method for the identification and tracking of substances of concern in products and for the preparation of restriction measures on the use of substances in products. The report lays out practical methods for identifying and tracking Substances of Concern (SoC) in products and throughout their lifecycle and offers the European Commission new tools for determining when and how to restrict hazardous substances. The guidance is designed to directly support the implementation of the Ecodesign for Sustainable Products Regulation (ESPR) (Regulation (EU) 2024/1781).

The ESPR, adopted by the Commission on June 13, 2024, and has been in force since July 18, 2024, represents a major expansion of the EU's product sustainability framework. Building on and replacing the earlier Ecodesign Directive, the ESPR extends regulation beyond energy efficiency to the full lifecycle environmental performance of products, introducing broader sustainability requirements and more comprehensive obligations for information disclosure.

1. Comprehensive Substance Information Requirements for Products

First, to track SoC throughout a product's lifecycle (as defined in Article 2(27) of the ESPR), the report defines the requirements for comprehensive substance information. A product's full substance information table should include recycled materials used in the product and materials recovered during end-of-life waste management. Furthermore, substances used during processes like manufacturing and transportation, even if not present in the final product, might also need to be disclosed in this comprehensive information. Additionally, for SoC, it is necessary to indicate whether they are intentionally added and provide attributes such as their function. The European Commission believes that with sufficiently complete information, tools like the Digital Product Passport (DPP), along with labels and tags, can effectively disseminate product information among businesses, organizations, consumers, and waste management operators.

2. Performance Requirements Related to the Presence or Use of Substances of Concern in Products

Secondly, the report proposes performance requirements concerning the presence or use of SoC in products. This indicates that future EU regulatory decisions on substance controls will not be limited solely to chemical safety. Primarily, materials/substances contained in products that negatively impact recycling processes after disposal will be considered for restriction. Similarly, materials/substances not present in the final product but whose use during the lifecycle negatively affects product performance will also be considered for restrictions. For instance, if the use of a specific material/substance results in an excessively high Environmental Impact (e.g., carbon footprint), that material/substance might be banned in the future. The regulatory requirements for product performance will be developed around the relationship between the product aspects listed in ESPR Article 5(1) and the presence/use of substances. Product performance primarily covers the following aspects: (a) durability; (b) reliability; (c) reusability; (d) upgradability; (e) reparability; (f) maintainability and possibility of refurbishment; (g) presence of Substances of Concern; (h) energy use and energy efficiency; (i) water consumption and water efficiency; (j) resource use and resource efficiency; (k) recycled content; (l) possibility of remanufacturing; (m) recyclability; (n) possibility of material recycling; (o) environmental impact, including carbon footprint and environmental footprint; (p) expected waste generation. The Life Cycle Assessment (LCA) methodology referenced in the ESPR is EF3.1.

CIRS Insights

The release of this methodological guideline signifies the EU's shift from solely controlling chemical hazards towards a more comprehensive management of environmental impact. Currently, the prevalent global approach for managing hazardous substances in products involves collecting Full Material Declaration (FMD) or Material Composition Data (MCD) along the supply chain. This typically includes information such as component structure, material name, material weight, material category, substance name, CAS/EC numbers, and substance concentration percentage. Based on the content of the latest regulation, companies can continue using this management model but may need to supplement it with additional material information, including: whether a substance is intentionally added, the proportion of recycled content, the lifecycle stage, and the substance's function. Furthermore, conducting a Life Cycle Assessment (LCA) for products is likely to become a standard routine practice. This implies that a comprehensive LCA might be required for each product exported to the EU to evaluate the environmental impact of factors like potential substitute materials.

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