The Biweekly Pulse: 24th February – 7th March 2025
The Pulse was originally posted on 12th March, 2025. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.
Check out what’s hot in our regulatory world with The Pulse! The Pulse is your biweekly source for global regulatory insights.
This week’s trending sources in C2P
- EU: Evaluation study on the Implementation of Article 4 of Regulation (EU) 2019/1020 on Market Surveillance and Compliance of Products, Report, February 2025
- UK: Product Regulations and Current Approaches to Product Marking for the GB Market, Guidance Document, February 2025
- China: Indicative Lists of PFAS Chemicals, Public Consultation, February 2025
What is our Content Team talking about?
Japan SSBJ issues Inaugural Sustainability Disclosure Standards to be applied in Japan
On 5 March 2025, the Sustainability Standards Board of Japan (SSBJ) announced the issuance of its inaugural sustainability disclosure standards (SSBJ Standards), comprising the following three Sustainability Disclosure Standards.
- Universal Sustainability Disclosure Standard “Application of the Sustaina…
- Theme-based Sustainability Disclosure Standard No. 1 “General Disclosures…
- Theme-based Sustainability Disclosure Standard No. 2 “Climate-related Dis…
These standards essentially incorporate the content of the IFRS Sustainability Disclosure Standards.
While the IFRS standards are divided into S1 and S2, the corresponding standards in Japan are provided as three separate standards. This is because IFRS S1 was divided into two standards in the Japan version.
The portion of IFRS S1 that outlines the fundamental requirements for preparing sustainability-related financial disclosures has been established as a separate standard, referred to as the “universal standard.” Meanwhile, the portion detailing the disclosure of sustainability-related risks and opportunities (referred to as “core content”) has been incorporated into the Japanese version of S1.
These standards do not specify the companies to which they apply or the timeline for when they become mandatory. It is expected that the applicable companies and the timeline for mandatory disclosure in line with the sustainability disclosure standards will be determined through related laws and regulations in the future.
If companies voluntarily choose to disclose in accordance with these standards, they can apply them to sustainability-related financial disclosures for annual reporting periods ending after the publication date of these standards.
Moreover, these standards (universal standard, S1, and S2) are to be applied simultaneously.
SSBJ Standards are available in the Japanese language only. Nevertheless, for the convenience of English speakers, the overview of SSBJ Standards is available in the English language. In addition, the schedule of differences and the table of concordance between ISSB Standards and SSBJ Standards in the English language will be published shortly.
SSBJ issues Inaugural Sustainability Disclosure Standards to be applied in Japan
About SSBJ Standards (the overview of SSBJ Standards in English)
What are our Knowledge Partners talking about?
EU publishes guidance on the removability and replaceability of batteries
by RINA
The EU has published guidance1 to support the requirements on the removability and replaceability of portable batteries and light means of transport (LMT) batteries in the EU Batteries Regulation2.
Article 11 of the Batteries Regulation is applicable from 18 February 2027 and contains requirements on the removability and replaceability of portable and LMT batteries for products incorporating them that companies placing those products on the EU market must meet.
The guidance provides context and technical details to support the application of the requirements on the removability and replaceability of portable and LMT batteries. It reflects input from discussions with Member States and stakeholders.
What does the guidance cover?
- Use of commercially available, specialized or proprietary tools
- Independent Professionals that remove and replace batteries
- Appliances operating in a wet environment
- Professional medical imaging, radiotherapy and in-vitro diagnostic medical devices
- Full derogations for end-user removability and replaceability
- Data integrity considerations
- Concept of compatible battery
- Availability as spare parts
- Software limitations
The guidance clarifies that a compatible battery must allow a device to function safely and as intended without violating product safety regulations. This means manufacturers must design devices to accommodate both original and compatible batteries, ensuring they meet technical parameters such as capacity, chemistry, and safety standards. For batteries in multi cell packs, individual cells must also be compatible without compromising safety.
Next Steps
Producers of portable batteries and LMT batteries incorporated into products that they place on the EU market should familiarize themselves with the guidance ahead of the entry into force of removability and replacement requirements in February 2027. Manufacturers should provide clear technical specifications for compatible batteries, ensuring safe replacement while preventing anti-competitive restrictions.
- C/2025/214 Commission guidelines to facilitate the harmonized application of provisions on the removability and replaceability of portable batteries and LMT batteries in Regulation (EU) 2023/1542 ↩︎
- Regulation (EU) 2023/1542, hereafter “the Batteries Regulation ↩︎
What are our clients asking about?
“Do spare parts need to be RoHS compliant?”
Answered by Joyce Costello
Yes. RoHS has been gradually extended to cover all electrical and electronic equipment and spare parts, subject to some exclusions:
Spare parts for the repair, the reuse, the updating of functionalities or upgrading of capacity of the following do not need to comply with EU RoHS:
- EEE placed on the market before 1 July 2006;
- medical devices placed on the market before 22 July 2014;
- in vitro diagnostic medical devices placed on the market before 22 July 2016;
- monitoring and control instruments placed on the market before 22 July 2014;
- industrial monitoring and control instruments placed on the market before 22 July 2017.
In other words, spare parts for the repair, the reuse, the updating of functionalities or upgrading of capacity for a specific product category, must comply from the same date as their respective product category. Following the principle of ‘repair as produced’, spare parts for the specific products already on the market before the dates mentioned above are exempted.
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