STP COMPLIANCE EHS REGALERT ROUND-UP

April 30th 2025

EU Packaging and Packaging Waste Regulation

The new  Packaging and Packaging Waste Regulation ( PPWR – Regulation (EU) 2025/40 ) marks a significant step towards the EU’s transition to a circular economy.  This Regulation repeals and replaces European Parliament and Council Directive 94/62/EC of 20 December 1994 on Packaging  and Packaging Waste to establish more concrete and easier-to-implement provisions for packaging minimization and recycling. According to the European Commission’s summary, the Regulation’s overarching goals are

The new  Packaging and Packaging Waste Regulation ( PPWR – Regulation (EU) 2025/40 ) marks a significant step towards the EU’s transition to a circular economy.  This Regulation repeals and replaces European Parliament and Council Directive 94/62/EC of 20 December 1994 on Packaging  and Packaging Waste to establish more concrete and easier-to-implement provisions for packaging minimization and recycling. According to the European Commission’s summary, the Regulation’s overarching goals are to make all packaging placed on the EU market recyclable by 2030, incorporate more recycled plastic into packaging and put the packaging sector on track for climate neutrality by 2050.  The Regulation establishes provisions on life-cycle packaging management, including sustainability requirements (such as recyclability, biobased feedstock, and compostability), labelling and marking requirements, and manufacturer obligations. Transitional provisions for replaced requirements are specified in Articles 70 and 71. It is worth noting that, as a Regulation, this measure applies directly to all EU Member States. Directive 94/62/EC would have required implementation in national legislation for EU Member States. Also, the Regulation applies to all packaging placed on the EU market regardless of where a company is headquartered.  The Regulation entered into force on February 11, 2025, with a general application date of August 12, 2026.  Further guidance on implementation timelines is expected in forthcoming standards and guidelines.

to make all packaging placed on the EU market recyclable by 2030, incorporate more recycled plastic into packaging and put the packaging sector on track for climate neutrality by 2050.  The Regulation establishes provisions on life-cycle packaging management, including sustainability requirements (such as recyclability, biobased feedstock, and compostability), labelling and marking requirements, and manufacturer obligations. Transitional provisions for replaced requirements are specified in Articles 70 and 71. It is worth noting that, as a Regulation, this measure applies directly to all EU Member States. Directive

94/62/EC would have required implementation in national legislation for EU Member States. Also, the Regulation applies to all packaging placed on the EU market regardless of where a company is headquartered.  The Regulation entered into force on February 11, 2025, with a general application date of August 12, 2026.  Further guidance on implementation timelines is expected in forthcoming standards and guidelines.

Warehouse Worker Ergonomics Standard

In June, New York will become the third state with mandatory ergonomics rules (after California and Minnesota). The Warehouse Worker Injury Reduction Program, signed by Governor Hochul on December 21st, applies to direct and indirect employers (defined as having control over the wages, hours, or working conditions) of at least one hundred employees at a single warehouse distribution center or at least one thousand employees at multiple warehouses. They must implement an ergonomics program that addresses musculoskeletal risks from any material handling work and take related steps to reduce those risks. The law prescribes that programs include annual written worksite evaluations, including recommendations from affected workers, analysis of findings, followed by timely implementation of corrective action. Injury reduction

In June, New York will become the third state with mandatory ergonomics rules (after California and Minnesota). The Warehouse Worker Injury Reduction Program, signed by Governor Hochul on December 21st, applies to direct and indirect employers (defined as having control over the wages, hours, or working conditions) of at least one hundred employees at a single warehouse distribution center or at least one thousand employees at multiple warehouses. They must implement an ergonomics program that addresses musculoskeletal risks from any material handling work and take related steps to reduce those risks. The law prescribes that programs include annual written worksite evaluations, including recommendations from affected workers, analysis of findings, followed by timely implementation of corrective action. Injury reduction training is required for “all employees involved in performing manual materials handling jobs and tasks at the warehouse during normal work hours and without suffering a loss of pay.”

The law was  amended on February 14th to clarify several points. “Work-related” was added to the defined term “musculoskeletal disorders,” and “competent person” replaced “qualified ergonomist” as the person eligible to conduct the evaluations. The list of risk factors increased to include extreme or static postures, direct pressure, contact stress, vibration, and cold temperatures. Other changes include a new employer obligation to incorporate worker input into written worksite evaluations and an exclusion for certain workplace safety committees formed before the effective date through collective bargaining. The effective date is June 1, 2025. The agency has a  webpage with more information.


training is required for “all employees involved in performing manual materials handling jobs and tasks at the warehouse during normal work hours and without suffering a loss of pay.”

The law was  amended on February 14th to clarify several points. “Work-related” was added to the defined term “musculoskeletal disorders,” and “competent person” replaced “qualified ergonomist” as the person eligible to conduct the evaluations. The list of risk factors increased to include extreme or static postures, direct pressure, contact stress, vibration, and cold temperatures. Other changes include a new employer obligation to incorporate worker input into written worksite evaluations and an exclusion for certain workplace safety committees formed before the effective date through collective bargaining. The effective date is June 1, 2025. The agency has a  webpage with more information.

New Canadian Petroleum Bulk Storage and Loading Regulations

On March 26, 2025, the Government of Canada issued the new  Reduction in the Release of Volatile Organic Compounds (Storage and Loading of Volatile Petroleum Liquids) Regulationsauthorized under the Canadian Environmental Protection Act, 1999 , establishing significant permanent national equipment-based requirements for new and existing volatile petroleum liquid storage tanks and loading operations at petroleum and petrochemical facilities (“regulated facilities”), aimed to reduce the risks presented by the release of volatile organic compounds (VOCs) during these activities. Key actionable requirements for facility operators include  1) installation of emissions control equipment on storage tanks and

On March 26, 2025, the Government of Canada issued the new  Reduction in the Release of Volatile Organic  Compounds (Storage and Loading of Volatile Petroleum Liquids) Regulationsauthorized under the  Canadian Environmental Protection Act, 1999, establishing significant permanent national equipment-based requirements for new and existing volatile petroleum liquid storage tanks and loading operations at petroleum and petrochemical facilities (“regulated facilities”), aimed to reduce the risks presented by the release of volatile organic compo unds (VOCs) during these activities. Key actionable requirements for facility operators include 1) installation of emissions control equipment on storage tanks and loading equipment/racks, 2) implementation of an inspection, maintenance, and repair process, and 3) undertaking record-keeping and reporting activities. The deadlines for regulated facilities to bring equipment into compliance are based on the equipment’s prior condition and emissions risk, with a phased-in implementation scheme that prioritizes the highest-emitting equipment. While most of the provisions in these Regulations came into force upon their registration (March 7, 2025), the obligation to use a temporary vapour control system under certain specified conditions, and action plan implementation requirements (in subsection 43(3) and section 49, respectively) have a delayed in force date of July 5, 2025.

loading equipment/racks, 2) implementation of an inspection, maintenance, and repair process, and 3) undertaking record-keeping and reporting activities. The deadlines for regulated facilities to bring equipment into compliance are based on the equipment’s prior condition and emissions risk, with a phased-in implementation scheme that prioritizes the highest-emitting equipment. While most of the provisions in these Regulations came into force upon their registration (March 7, 2025), the obligation to use a temporary vapour control system under certain specified conditions, and action plan implementation requirements (in subsection 43(3) and section 49, respectively) have a delayed in force date of July 5, 2025.

India Revises Waste Battery Rules with a Focus on EPR

Battery producers and dealers can now take advantage of new exemptions and streamlined labelling requirements issued under the  Battery Waste Management Amendment Rules, 2025,  effective February 24, 2025. The amendment aims to refine and facilitate extended producer responsibility (EPR) requirements applicable to battery producers, dealers, consumers, and entities involved in the collection, segregation, transportation, re-refurbishment and recycling of waste batteries. The Rules apply to all types of batteries regardless of chemistry, shape, volume, weight, material

Battery producers and dealers can now take advantage of new exemptions and streamlined labelling requirements issued under the   Battery Waste Management Amendment Rules, 2025,   effective February 24, 2025. The amendment aims to refine and facilitate extended producer responsibility (EPR) requirements applicable to battery producers, dealers, consumers, and entities involved in the collection, segregation, transportation, re-refurbishment and recycling of waste batteries. The Rules apply to all types of batteries regardless of chemistry, shape, volume, weight, material composition and use. The Amendments make changes to the 2022 labelling requirements presented in Schedule I, including exempting registration number labelling for packaging covered under rule 26 of the Legal Metrology (Packaged Commodities) Rules, 2017, and permitting barcodes or Quick Response (QR) codes displaying their EPR registration number as opposed to worded labelling, as long as the producer enters the electronic information into a list maintained by the Central Pollution Control Board. An exemption is also added from the mandatory chemical symbol markings for cadmium (Cd) and lead (Pb) when Cd concentrations are below 0.002% (20 ppm) and Pb concentrations are below 0.004% (40 ppm).

composition and use. The Amendments make changes to the 2022 labelling requirements presented in Schedule I, including exempting registration number labelling for packaging covered under rule 26 of the Legal Metrology (Packaged Commodities) Rules, 2017, and permitting barcodes or Quick Response (QR) codes displaying their EPR registration number as opposed to worded labelling, as long as the producer enters the electronic information into a list maintained by the Central Pollution Control Board. An exemption is also added from the mandatory chemical symbol markings for cadmium (Cd) and lead (Pb) when Cd concentrations are below 0.002% (20 ppm) and Pb concentrations are below 0.004% (40 ppm).

Malaysia Rolls Out Safety Inspection Certification Program for Industrial Equipment

Malaysian facilities must now confirm their industrial equipment is properly certified and complies with enhanced operational and inspection requirements based on new regulations that took effect January 20, 2025. Malaysia’s Ministry of Human Resources has issued revised regulations for the inspection and certification of equipment (“plants”) requiring a certificate of fitness, such as steam boilers, pressure vessels, and lifting machinery, as specified under the  Occupational Safety and Health (Special Inspection Scheme) Regulations 2025. The regulations implement the inspection and certification program required under Section 27D of the Occupational Safety and Health Act 1994, which provides that companies may not operate any plant requiring a Certificate  of Fitness without first obtaining such certificate from the

Malaysian facilities must now confirm their industrial equipment is properly certified and complies with enhanced operational and inspection requirements based on new regulations that took effect January 20, 2025. Malaysia’s Ministry of Human Resources has issued revised regulations for the inspection and certification of equipment (“plants”) requiring a certificate of fitness, such as steam boilers, pressure vessels, and lifting machinery, as specified under the  Occupational Safety and Health (Special Inspection Scheme) Regulations 2025. The regulations implement the inspection and certification program required under Section 27D of the Occupational Safety and Health Act 1994, which provides that companies may not operate any plant requiring a Certificate of Fitness without first obtaining such certificate from the Department of Occupational Safety and Health (DOSH). The 2025 regulations replace the previous plant inspection and certification regulations from 2014.  The program is intended to ensure the safety and integrity of industrial plants through rigorous inspection and compliance measures as part of a company’s safety management program. Specifically, the regulation introduces two classes of inspection schemes: Class A for steam boilers and pressure vessels, and Class B for all plants requiring certification, including lifting machinery. The validity of certificates is capped at 60 months.  Under the program, facilities must apply for approval, meet specific requirements, and maintain risk-based data, inspection plans, and safety management systems. The regulations outline the duties of facilities for each plant class as well as the process for special inspections, the conditions for revocation or termination of the inspection schemes, and program fees.

Department of Occupational Safety and Health (DOSH). The 2025 regulations replace the previous plant inspection and certification regulations from 2014.  The program is intended to ensure the safety and integrity of industrial plants through rigorous inspection and compliance measures as part of a company’s safety management program. Specifically, the regulation introduces two classes of inspection schemes: Class A for steam boilers and pressure vessels, and Class B for all plants requiring certification, including lifting machinery. The validity of certificates is capped at 60 months.  Under the program, facilities must apply for approval, meet specific requirements, and maintain risk-based data, inspection plans, and safety management systems. The regulations outline the duties of facilities for each plant class as well as the process for special inspections, the conditions for revocation or termination of the inspection schemes, and program fees.

Released-Based Cleanup Regulations Come to Connecticut

On January 24, Connecticut’s Department of Energy and Environmental Protection (DEEP) published its   Release Based Cleanup Regulations (RBCRs), replacing the state’s Transfer Act as the primary remediation site cleanup program. The regulations await Connecticut General Assembly approval and have a proposed effective date of March 1, 2026.  

Under Connecticut’s new release-based, risk-based approach, property transfers will no longer trigger mandatory investigations into historical contamination. Instead, investigations will occur at the discretion of the property owner as part of their environmental due diligence. Reviewing historical records that suggest a past release will not, on its own, require reporting. Accordingly, any person who creates or maintains (discovers) a new or newly discovered historical release will be responsible for reporting and remediating the release. This shift brings Connecticut in line

On January 24, Connecticut’s Department of Energy and Environmental Protection (DEEP) published its   Release Based Cleanup Regulations (RBCRs), replacing the state’s Transfer Act as the primary remediation site cleanup program. The regulations await Connecticut General Assembly approval and have a proposed effective date of March 1, 2026.  

Under Connecticut’s new release-based, risk-based approach, property transfers will no longer trigger mandatory investigations into historical contamination. Instead, investigations will occur at the discretion of the property owner as part of their environmental due diligence. Reviewing historical records that suggest a past release will not, on its own, require reporting. Accordingly, any person who creates or maintains (discovers) a new or newly discovered historical release will be responsible for reporting and remediating the release. This shift brings Connecticut in line  with nearly every other state’s cleanup framework.

The RBCRs retain and recodify existing soil and groundwater standards and add new risk-based cleanup approaches related to the release reporting rules. These approaches prioritize completing release cleanups within a year of occurrence, with set objectives and require site inspections to undergo technical analysis. Releases for which cleanup will take more than a year require reporting and are subject to new risk-based, tiered cleanup alternatives, where less dangerous releases will be subject to less stringent requirements. They include new permits-by-rule that streamline managing polluted soil below buildings and hard surfaces and eliminate the need to excavate when the property is used for commercial or industrial uses.

Additional details on these changes are available on DEEP’s   Release-Based Cleanup Program Regulation Development webpage. 



with nearly every other state’s cleanup framework.

The RBCRs retain and recodify existing soil and groundwater standards and add new risk-based cleanup approaches related to the release reporting rules. These approaches prioritize completing release cleanups within a year of occurrence, with set objectives and require site inspections to undergo technical analysis. Releases for which cleanup will take more than a year require reporting and are subject to new risk-based, tiered cleanup alternatives, where less dangerous releases will be subject to less stringent requirements. They include new permits-by-rule that streamline managing polluted soil below buildings and hard surfaces and eliminate the need to excavate when the property is used for commercial or industrial uses.

Additional details on these changes are available on DEEP’s   Release-Based Cleanup Program Regulation Development webpage.