News from the EXFO that can make compliance managers’ lives easier
…if you have them on your radar early enough.
On February 12, the Expert Forum (EXFO) at Fraunhofer IPA met for the first time this year. Our colleague Simon Brack attended on behalf of Substantio and brought back the latest insights from the material compliance world:
“What I value about the Expert Forum is that it’s a protected space where everyone dealing with material compliance can exchange in real depth. That’s exactly why people speak openly about the real challenges and the cost of implementation. And we look for pragmatic solutions together.”
Here are Simon’s key takeaways:
1
PPWR: Packaging & Packaging Waste Regulation - top of mind because it will soon be binding
The PPWR will apply from August 12, 2026 (in force since February 11, 2025).
In practice, this means: your ability to demonstrate compliance (recyclability/reuse) depends on reliable data on packaging, materials, and substances.
What Substantio provides:
A central, auditable data foundation for packaging and material data (instead of isolated spreadsheets and supplier back-and-forth) – so you can generate evidence faster and keep changes under control.
2
ESPR & the Digital Product Passport: the data question will decide
Under the ESPR, the Digital Product Passport (DPP) becomes a central mechanism.
And: the European Commission is expected to provide a Digital Product Passport Registry by July 19, 2026 (e.g., for product unique identifiers).
What Substantio provides:
Material and substance data from a single source – a solid foundation for creating DPPs.
3
PFAS: more obligations worldwide - reporting and bans continue to roll out
PFAS requirements are becoming more complex internationally – which is exactly why supply chain transparency is turning into a bottleneck.
Examples from the U.S. that Simon found particularly relevant:
- Minnesota: PFAS-in-products reporting – the authority extended the initial deadline to July 1, 2026.
- New Mexico: laws covering phase-outs/bans and reporting are underway (with stages and exemptions).
What Substantio provides:
Fast answers to the question: “Where could PFAS be present in my supplied parts?”
In the next step, Substantio provides structured data for supplier declarations, assessments, and reporting.
4
RoHS: finally more clarity and, in the medium term, more centralization
Not new, but always worth revisiting: there is a central overview of RoHS exemptions.
The European Commission provides an updated Exemptions List (Annex III/IV).
And: as part of “one substance, one assessment,” responsibilities around RoHS exemptions are increasingly moving to ECHA – with the aim of creating future simplifications through harmonization.
Link RoHS exemptions cleanly to your material data – so assessments remain reproducible and updates don’t create unnecessary extra effort.
“It’s worth looking at these topics through a solution lens: How can we absorb the requirements and the developments in material compliance in a way that makes implementation efficient for companies? That’s why we stay close to the topic and continuously evolve our software - so our customers can manage material compliance easily and in an automated way in the future as well.”
The next EXFO update will follow after the next meeting at the end of March.
