The firm’s Product & Consumer Protection Mid-year Review 2026, now in its fifth year, examines regulatory developments affecting businesses that place products on the EU market, covering safety, sustainability, AI and digital platforms.

Michaela Herron, partner and head of products at Mason Hayes & Curran, said: “The first half of 2026 has brought a fresh round of change in product regulation on various fronts. Businesses are having to look again at product formulations, sustainability claims, online sales journeys and AI governance. Our Mid-year Review sets out what has changed and what needs to happen next.”

The publication covers recent changes to the EU Cosmetic Products Regulation, including bans on 18 newly classified harmful substances that took effect from 1 May 2026. It also looks at further deadlines ahead on fragrance allergens in July and PFAS restrictions in October. These deadlines will require manufacturers to review formulations and update safety assessments without delay.

It examines the new regime for sustainability product claims. From 27 September 2026, businesses will face stricter restrictions on environmental and social claims made to consumers. Certain claims, including generic environmental claims and unsupported carbon neutral assertions, will be prohibited outright, with a stronger focus on substantiation.

The publication also examines the European Commission’s draft Guidelines on high-risk AI classification, published on 19 May. The review sets out how providers should assess whether their AI systems fall within the high-risk category under the AI Act, and flags areas, including value chain responsibilities and the concept of substantial modification, that still require further guidance.

Anna Lundy, of counsel, at Mason Hayes & Curran, said: “Much of this is now operational. The legal requirements are reasonably well understood, but what regulators want to see are the records, the processes and the supplier information that back them up – and pulling that together takes time.”