BPA out, PFAS capped: the EU packaging squeeze
Regulatory Pressure Index, Q3 2026: which rules created the most reformulation, testing and relabelling work, and where it landed.
Most regulatory updates are lists. They say what changed and leave R&D teams to work out what it means for the formulas on their bench. The Regulatory Pressure Index starts from the other end. It scores each rule by the reformulation, testing and relabelling work it creates, and shows which industries it lands on.
This first issue covers July to September 2026 and sets the baseline for future quarters. It scores 25 regulatory moves across the EU, the UK and the US, plus China for batteries, in five industries: food and beverage; paints, coatings and adhesives; cosmetics and personal care; plastics and polymers; and batteries.
Which regulations created the most work for R&D teams in Q3 2026?
Two EU rules, the BPA ban in food contact and the packaging regulation (PPWR), scored 45 of the quarter's 149 points, about 30%. They took effect 23 days apart, on 20 July and 12 August 2026, and reached three industries at once: can coatings and adhesives, food-contact plastics, and the food and drink makers who use them.
Food and beverage scored highest, at 42, just ahead of paints, coatings and adhesives (40), then cosmetics and personal care (30), plastics and polymers (20) and batteries (17). EU rules made up 50% of all points.
What the quarter tells us
Q3 2026 was a quarter of deadlines, not proposals: 19 of the 25 scored moves were already in force or due within a year. The report sets out four patterns:
- Food-contact packaging was the pressure point. A single packaging change now means reformulation work for several suppliers in the chain.
- PFAS pressure is arriving as data requests before bans. PFAS limits in EU food packaging now apply, and Minnesota's reporting deadline scored in four of the five industries.
- In the US, the states are doing the work. About 80% of US points came from state laws, including PFAS reporting and school-meal dye bans.
- The UK and EU are drifting apart, for now. Great Britain set its own cosmetics bans while postponing the BPA ban the EU has already applied.
How the index is scored
Each regulatory move published, adopted or taking effect in the quarter scores 1 to 3 points on each of three factors: stage, reformulation impact and reach, for a total of 3 to 9. An industry's index is the sum of its moves' scores, so it rises with both the number and the weight of changes. Only moves that would make an R&D team change a formula, a test plan or a label count. From Q4 2026, each industry also shows its change from the previous quarter.
Who this report is for
R&D and regulatory leaders in chemicals and materials who need to plan reformulation, testing and relabelling work across the EU, UK, US and China markets.
For a one-page overview of how Uncountable approaches this, read the solution brief Regulatory Management: check regulations while you formulate.
What's inside
Inside this report:
- Index scores for five industries, broken down by region and by regulatory move
- What the quarter tells us: four patterns behind the scores
- Industry sections for food and beverage; paints, coatings and adhesives; cosmetics and personal care; plastics and polymers; and batteries, with what R&D teams need to do for each move
- A substance watchlist with CAS numbers, including BPA, PFAS, PFHxA, TPO, 4-MBC, Red 40 and titanium dioxide
- Coming up: eight dates that land by mid-February 2027
- Seven pending decisions that will shape the next issues, starting with the EU-wide PFAS restriction
- Recommended actions for Q4 2026 and 2027 preparation
Start with the substance watchlist, and check how quickly you could list every formula that contains each entry and every market those formulas are sold in. Download the report.
FAQs
The Regulatory Pressure Index is a quarterly report from Uncountable that scores regulatory moves by the reformulation, testing and relabelling work they create for R&D teams, and shows which industries each move lands on. The first issue covers July to September 2026 and sets the baseline for future quarters.
Each regulatory move published, adopted or taking effect in the quarter scores 1 to 3 points on stage, reformulation impact and reach, for a total of 3 to 9. An industry's index is the sum of its moves' scores. Only moves that would make an R&D team change a formula, a test plan or a label count, and a move that hits two industries counts in both.
Food and beverage scored highest in Q3 2026, at 42, driven by two EU packaging deadlines and a run of US school-meal dye bans. Paints, coatings and adhesives followed at 40, then cosmetics and personal care (30), plastics and polymers (20) and batteries (17).
The EU BPA ban in food contact, whose transition ended on 20 July 2026, and the EU packaging regulation (PPWR), which applied from 12 August 2026, together scored 45 of the quarter's 149 points, about 30%. They reached can coatings and adhesives, food-contact plastics, and the food and drink makers who use them.
The index covers five industries: food and beverage; paints, coatings and adhesives; cosmetics and personal care; plastics and polymers; and batteries. It covers the EU, the UK, US federal agencies and US states, plus China for batteries. The report is a summary for R&D planning, not legal or compliance advice.
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