--- title: "A new regulation applies and nobody knows what changes" description: "A new EU regulation rarely changes everything at once. It names the products it covers, the roles it binds and the dates its duties start, and those dates are often years apart. To find out what changes for you, list the products in scope, read your role's articles, separate the date of application from the later phase-in dates, and compare the result with the documents you already hold." type: "problem" url: "https://www.conphora.com/solutions/problem/new-regulation/" markdown: "https://www.conphora.com/solutions/problem/new-regulation.md" locale: "en" language: "en" updated: "2026-10-05" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/eli/reg/2023/988/oj" tags: ["GPSR", "BattR", "PPWR", "placing-on-market"] license: "Free to quote with attribution and a link to the page" --- # A new regulation applies and nobody knows what changes A new EU regulation rarely changes everything at once. It names the products it covers, the roles it binds and the dates its duties start, and those dates are often years apart. To find out what changes for you, list the products in scope, read your role's articles, separate the date of application from the later phase-in dates, and compare the result with the documents you already hold. ## Why this happens EU product law arrives as regulations that apply directly in every Member State. Each one is built the same way: a scope article that names the products, definitions that name the roles, articles with duties per role, and final provisions with the dates. Most of the confusion comes from reading the summary of an act and not these four parts. [1] The dates are the part that is most often misread. The General Product Safety Regulation applies from 13 December 2024. The Battery Regulation applies from 18 February 2024, but its duties start in stages: labelling, due diligence and the battery passport each have their own date, the passport on 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. [2] The Packaging and Packaging Waste Regulation applies from 12 August 2026. [3] A regulation also reaches you through your customers. A distributor has to verify parts of your compliance before selling the product, and a marketplace has to show your data on the listing, so the first question about a new act usually comes from a retailer and not from an authority. [1] The Digital Product Passport follows a different pattern again. The Ecodesign for Sustainable Products Regulation is a framework: it sets no product requirements by itself, and each product group gets its rules and its passport through a delegated act. [5] ## How to solve it 1. **List the acts that touch your catalogue** Go through the catalogue by product type and note every act whose scope article covers it. A battery-powered toy in a printed box sits under four acts, not one. 2. **Read the dates, not the headline** An act has a date of entry into force, a date of application and often later dates for single duties. The Battery Regulation applies from 18 February 2024, while the battery passport starts on 18 February 2027. 3. **Find your role in each act** Manufacturer, importer and distributor have different articles. A company that sells under its own brand carries the manufacturer's duties even when someone else makes the product. 4. **Check each product against the duties that apply now** Record per product what is met, what is missing and which supplier has to deliver it. The gaps become your work list. 5. **Follow the changes that are still to come** Delegated acts, guidance and amended dates arrive after the regulation itself. Follow them per regulation so the next date does not come as a surprise. ## What you need to show - **A list of regulations per product** — Your own scope assessment, product type by product type (The scope article of each act) - **Updated technical documentation** — The manufacturer, when a new act adds requirements (The act's article on technical documentation) - **A new or amended EU declaration of conformity** — The manufacturer, when the product falls under a further harmonisation act (One declaration naming every act that applies) - **Supplier declarations and test reports** — Suppliers and laboratories, for the new requirements (Supports the technical documentation) ## If you do nothing - **Products stopped at the date of application** — From that date a product placed on the market must meet the new rules. Market surveillance authorities can require corrective action, withdrawal or recall (Regulation (EU) 2019/1020, Article 16). - **Penalties under national law** — Member States lay down the penalties for infringements of the Union harmonisation legislation listed in Annex II to Regulation (EU) 2019/1020 that imposes obligations on economic operators (Article 41); other acts carry their own penalty articles. - **Retailers ask before authorities do** — Distributors have their own verification duties under the GPSR (Article 12), so their questions often arrive before the date of application. ## Questions ### Do products already on the market have to change? That depends on the act's transitional provisions. Under the GPSR, products that complied with the former directive and were placed on the market before 13 December 2024 may still be made available (Article 51). ### What is the difference between entry into force and application? Entry into force makes the act law. The date of application is when its duties start to bind companies, and it is usually later. Single duties can have later dates still. ### When does the Packaging and Packaging Waste Regulation apply? Regulation (EU) 2025/40 applies from 12 August 2026, with many of its targets and requirements phased in over the following years. ### What is the Digital Product Passport, and when does it start? The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 sets the framework. The passport becomes mandatory product group by product group through delegated acts, so the start date depends on your product. ## Regulations involved GPSR, BattR, PPWR ## Sources 1. [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/eli/reg/2023/988/oj) — EUR-Lex, 2026-09-21 2. [Regulation (EU) 2023/1542 concerning batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj) — EUR-Lex, 2026-09-21 3. [Regulation (EU) 2025/40 on packaging and packaging waste](https://eur-lex.europa.eu/eli/reg/2025/40/oj) — EUR-Lex, 2026-09-21 4. [Regulation (EU) 2019/1020 on market surveillance and compliance of products](https://eur-lex.europa.eu/eli/reg/2019/1020/oj) — EUR-Lex, 2026-09-21 5. [Regulation (EU) 2024/1781 establishing a framework for ecodesign requirements for sustainable products](https://eur-lex.europa.eu/eli/reg/2024/1781/oj) — EUR-Lex, 2026-09-21