REF-10 Workshop Reveals Persistent Challenges in EU Chemical Compliance
A significant 81% of participants recognised the presence of "free riders" who avoid compliance duties.
The European Commission has launched infringement proceedings against 27 Member States for failing to fully transpose 11 EU directives, impacting industries from chemicals to electronics and finance. Formal notices were issued on 31 January 2025, giving Member States two months to comply or face further legal action.
Key Insights
Manufacturers Face Compliance Uncertainty
The affected directives include air pollutant emissions, hazardous substances in electronics (RoHS), financial regulations (Daisy Chains II), VAT schemes, and corporate gender balance requirements. Businesses across the manufacturing supply chain, chemicals, electronics, and financial sectors now face uncertainty regarding compliance obligations.
Key Directives Under Scrutiny
Hazardous Substances in Electronics: RoHS Directive
Cyprus failed to transpose Commission Delegated Directive (EU) 2024/1416, amending the Restriction of Hazardous Substances (RoHS) Directive 2011/65/EU. This directive narrows exemptions for cadmium in LED applications, requiring businesses to seek alternative materials and update compliance strategies.
Air Pollutant Emission Projections
Bulgaria, Denmark, Germany, Cyprus, Hungary, The Netherlands, Portugal, Slovakia, and Finland missed the 31 December 2024 deadline to transpose Directive (EU) 2024/299, aligning EU reporting with UN pollution standards. Failure to comply could lead to reporting penalties.
Financial Sector: Daisy Chains II Directive
Seventeen Member States, including France, Germany, and Italy, failed to implement the Daisy Chains II Directive (EU) 2024/1174, which restructures minimum capital requirements for banks and investment firms. This regulatory gap could create market uncertainty for financial institutions and service providers.
Compliance Deadlines and Business Implications
5 December 2024 – Transposition deadline for the Ferry Safety Directive.9 December 2024 – Implementation of the EU Emergency Travel Document.31 December 2024 – Key deadlines for RoHS, VAT, and air pollution directives.28 December 2024 – Corporate gender balance directive compliance date.
Manufacturers, importers, and service providers should assess supply chain risks, ensure product compliance, and prepare for potential enforcement actions. The Commission may escalate non-compliance cases to the Court of Justice of the EU, leading to financial penalties and trade restrictions.
Source:
ec.europa.eu
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