On July 22, 2026, the European Commission officially issued Regulation (EU) 2026/1189, adding mineral oil aromatic hydrocarbons (MOAH) to the restricted substances list in Annex XVII of REACH and clarifying that, from January 1, 2027, the MOAH content in rubber sealing rings, squeegee strips, cushioning pads, and other components used in photovoltaic cleaning equipment sold to the EU market must not exceed 0.1% (w/w). This change is directly related to material selection, export compliance, inspection documents, and delivery arrangements for photovoltaic cleaning equipment, and has particularly practical implications for Chinese suppliers serving the EU market. It therefore warrants the prompt attention of relevant companies across the industry chain.

Confirmed Contents of This Regulatory Adjustment

According to the information provided, the European Commission officially issued Regulation (EU) 2026/1189 on July 22, 2026, adding MOAH to the restricted substances list in Annex XVII of REACH.

The regulation will take effect on January 1, 2027. It applies to rubber sealing rings, squeegee strips, cushioning pads, and other components used in all photovoltaic cleaning equipment sold to the EU. The upper limit for MOAH content in these components is 0.1% (w/w).

The information provided also indicates that this limit is stricter than the current ISO 21469 standard. For Chinese suppliers, the currently specified response measures include replacing existing materials with food-grade hydrogenated nitrile butadiene rubber (HNBR) or fluorosilicone rubber and providing third-party MOAH test reports.

The Initial Impact Will Be on Materials, Exports, and Verification

Material Procurement Requires Synchronized Adjustments to Selection Criteria

For raw material purchasing companies and component procurement teams, the initial impact will be reflected in the selection of materials for rubber components. Since the information provided clearly states that Chinese suppliers need to replace materials with food-grade HNBR or fluorosilicone rubber, the procurement process must focus on whether existing sealing rings, squeegee strips, cushioning pads, and other components still meet the requirements for sales to the EU, as well as whether subsequent procurement specifications, technical requirements, and supplier certification documents need to be updated accordingly.

Processing, Manufacturing, and Complete-Unit Export Require Compliance Reassessment

For processing and manufacturing companies and photovoltaic cleaning equipment exporters, this change concerns not only whether individual rubber components meet the requirements, but also the compliance review of complete units before delivery to the EU. Based on the analysis, companies whose products contain the relevant rubber components and are sold to the EU market will need to recheck their bills of materials, component material descriptions, and testing documents to avoid compliance obstacles caused by MOAH limits during shipment, acceptance, or customer audits.

Testing and Certification Services Will Receive Greater Attention

For testing service providers and service companies responsible for compliance support, third-party MOAH test reports have become key documents in this regulatory change. In the future, companies are likely to pay closer attention to the consistency between test reports and technical documents during project bidding, customer factory audits, preparation of shipping documents, and after-sales traceability. This means that testing, report issuance, and document archiving will be integrated more directly into export business processes.

Purchasers and Distribution Channels Will Raise Document Review Requirements

For EU-market purchasers, channel distribution companies, and equipment integration procurement teams, the regulatory change will translate into more specific supplier qualification requirements. Purchasers are likely to include material descriptions, third-party MOAH test reports, and related technical documents as prerequisites for supply. This will affect supplier screening, order confirmation, and the pace of delivery acceptance.

What Practical Changes Should Companies Focus on Now?

First Verify Whether Existing Components Fall Within the Restricted Scope

Companies should first identify the rubber sealing rings, squeegee strips, cushioning pads, and other components used in products sold to the EU, and confirm whether these components fall within the scope of the new restrictions. This step is particularly important for companies supplying multiple markets, because the same product line may face different material and documentation requirements depending on the destination market.

Coordinate Material Replacement and Testing Preparation

The information provided has already specified a relatively clear direction for material adjustment: replacing materials with food-grade HNBR or fluorosilicone rubber. Based on the analysis, companies should not limit material replacement to procurement substitution alone. They should also arrange the preparation of third-party MOAH test reports at the same time. Otherwise, even after the material transition is completed, gaps may still arise in the documentation for supply to the EU.

Update Technical Documents and Customer Communication Simultaneously

From a practical perspective, affected companies need to check whether technical specifications, material descriptions, inspection documents, and product documents submitted externally are consistent with the new requirements. In particular, the wording of MOAH limits, material names, and third-party testing conclusions should remain consistent across tender documents, customer technical confirmations, and delivery documentation to avoid inconsistencies between documents.

Continue Monitoring Implementation Practices Rather Than Assuming the Outcome

What has currently been clarified includes the publication of the regulation, its implementation date, applicable product categories, and limit requirements. However, the input information does not elaborate on more detailed implementation procedures. Companies should continue to monitor official statements, customer procurement documents, testing requirements, and actual audit practices to avoid treating implementation details that have not yet been clarified as established conclusions.

From an Industry Perspective, This Is More Like a Compliance Signal That Has Entered the Implementation Stage

Based on the analysis, this information should not be understood merely as a general policy trend. It is more appropriately understood as a compliance change with a clearly defined implementation date and specific limit requirements. This is because the regulation number, publication date, implementation date, and applicable product categories have all been specified, while requirements for material replacement and third-party testing reports have already been transmitted directly to supply chain operations.

However, it should not yet be simply summarized as a matter whose market impact is already completely clear. How the market will implement these requirements in procurement, acceptance, project documentation, and after-sales traceability still requires further observation based on actual implementation. Industry attention should focus not only on the regulatory text itself, but also on how customers incorporate it into procurement conditions, how suppliers submit supporting materials, and how testing documents become part of delivery requirements.

For Market Participants, the Key Is to Complete Interface Adjustments in Advance

Overall, the core of this change is not the introduction of an abstract environmental or chemical substance concept, but the establishment of a more specific market-access threshold for rubber components used in photovoltaic cleaning equipment sold to the EU. For exporters, component suppliers, purchasers, and testing service providers, it is currently more appropriate to understand this as a regulatory change that has entered the preparation stage for implementation.

From a rational perspective, its market effects should not be exaggerated at this stage, nor should subsequent implementation details be regarded as fully determined. A more prudent understanding is that the regulatory requirements have been clarified, and companies across the industry chain need to complete preparations as soon as possible around materials, testing, documentation, and delivery interfaces, while continuing to track subsequent implementation practices and market feedback.

Basis of This Article and Directions for Further Verification

This article was generated based on the information title, event date, and event summary provided by the user. The information used includes the publication date and implementation date of Regulation (EU) 2026/1189, its applicable objects, MOAH limit requirements, the comparison with the current ISO 21469 standard, and the requirements for Chinese suppliers to replace relevant materials and provide third-party MOAH test reports.

For events of this type, continued verification is generally required using official announcements, publications from regulatory authorities, information from trade authorities, industry association information, documents issued by standards organizations, and reports from authoritative media. Since no specific official source links were provided in the input, the relevant original links and formally issued texts still require ongoing verification.

Items worth continuing to monitor include whether further explanations of the detailed policy rules are issued, whether certification or testing implementation practices are further clarified, whether tender documents and procurement requirements are adjusted accordingly, and whether new changes emerge in industry feedback and the actual implementation by companies.