For 36 years, the Joint Technical Liaison Meeting (JTLM) has helped provide product compliance professionals in the non-road equipment manufacturing industry with the requisite knowledge they need to help their organizations maintain market access around the world.
AEM was proud to host the 2026 edition of the event, held June 2-4, in Dallas, Texas, which offered an in-person forum for various trade associations to share their thoughts and perspectives on issues of common concern for non-road equipment manufacturers and “compare notes” regarding standards and regulatory activities happening in their respective regions.
What follows is the third in a four-part series of AEM Industry Advisor articles that highlight some of the key details of presentations and discussions from the 36th edition of the JTLM. Read the full PDF and Part 1 of the JTLM article series to gain a comprehensive look at the industry issues covered at last month’s JTLM.
U.S. Autonomy Issues and Technology Updates
AEM’s day two technology update focuses on autonomy, cybersecurity, and California’s emerging approach to autonomous agricultural equipment, which could influence other off-road sectors. AEM supports risk-based, performance-oriented safety rules and is advancing autonomous machine symbols, a voluntary CNA launch for vulnerability coordination on Jan. 1, 2027, and position work on EU Machinery Regulation concerns.
EPA
TSCA 8(a)7: PFAS Reporting
EPA’s TSCA Section 8(a)(7) PFAS rule originally required broad one-time reporting for PFAS or PFAS-containing articles manufactured or imported from 2011–2022, with no major article or trace-level exemptions. EPA’s November 2025 proposal would narrow the rule through exemptions for imported articles, PFAS at or below 0.1% by weight, byproducts, impurities, non-isolated intermediates, and R&D chemicals, with AEM awaiting the final rule before advising members on compliance strategy.
TSCA: Risk Assessment and Canada Update
EPA has proposed TSCA risk-evaluation revisions that would move toward a risk-based framework focused on actual conditions of use, exposures, workplace protections, use-by-use determinations, and more predictable timelines. Canada’s update covers PFAS risk management excluding fluoropolymers, NMP/NEP and flame-retardant assessments, restrictions on Dechlorane Plus and DBDPE, beginning June 30, 2026, and Federal Plastics Registry obligations relevant to packaging and industrial or commercial plastic reporting.
HFC: Phasedown Rulemaking
EPA’s HFC Technology Transitions Regulation restricts HFC use in covered sectors, including nonroad vehicle mobile air-conditioning beginning Jan. 1, 2028, with HFO-1234yf available through SNAP approval. Reporting has applied since Jan. 1, 2025, labelling aligns with each subsector’s effective date, and the rule does not restrict used equipment sales, distribution, export, repair, servicing, component replacement, or useful-life maintenance.
United States: PFAS
Minnesota
Minnesota’s PFAS program is moving from reporting into implementation, with the final reporting rule in effect, a July 1, 2026, effective date, and a PRISM reporting deadline currently set for Sept. 15, 2026. Manufacturers should track PRISM guidance, fees, enforcement expectations, and the Currently Unavoidable Use process, which may provide time-limited exemptions where PFAS uses are essential and alternatives are not reasonably available.
New Mexico
New Mexico’s PFAS Protection Act and final labeling rule create product-labeling obligations effective Jan. 1, 2027, for products with intentionally added PFAS, with waiver requests due by Oct. 31, 2026. The final rule removed earlier complex-durable-goods manual and component-location requirements, while product bans phase in from 2027 through 2032 for selected categories.
Other States
Other state PFAS activity remains concentrated on consumer-product restrictions, including a limited Illinois bill beginning in 2032 and California’s AB 872 failing this cycle. Although these measures are less directly focused on complex durable goods, manufacturers should continue tracking both enacted laws and failed proposals that may return, especially in states that influence broader environmental policy trends.
U.S. States: Extended Producer Responsibility (EPR)
State EPR laws increasingly require producers to fund recycling and waste management systems for packaging and paper products introduced into a state, including boxes, bags, shrink wrap, fillers, manuals, catalogs, and brochures. Producers generally must join a Producer Responsibility Organization, report packaging data, and pay fees, with Oregon and Colorado active, California expected in 2027, and Minnesota, Maryland, Maine, and Washington still developing programs.
The AEM update summarized the evolving U.S. extended producer responsibility landscape, where states are increasingly requiring producers to fund recycling and waste management systems for packaging and paper products introduced into the state, including cardboard boxes, plastic bags, shrink wrap, fillers, manuals, catalogs, and brochures. A producer is generally the brand owner or manufacturer selling or distributing packaged products in the state, with importers potentially responsible where no U.S. brand owner exists, and obligations typically include joining a Producer Responsibility Organization, reporting packaging data, and paying program fees. Oregon and Colorado are already active, with Oregon’s program operational as of July 1, 2025, and Colorado’s program starting in January 2026, while California is expected to begin in 2027 with longer-term packaging targets, and Minnesota, Maryland, Maine, and Washington remain in development. Circular Action Alliance has been selected as the designated Producer Responsibility Organization in states actively implementing EPR programs so far, creating a national compliance through-line, though program scope, thresholds, exemptions, and reporting timelines still vary by state.
OEHHA: Proposition 65
California Proposition 65 developments include updated safe-harbor warning methods effective Jan. 1, 2025, with new warning requirements due by Jan. 1, 2028. AEM is pursuing practical relief for non-road equipment parts, including possible technical amendments similar to the automotive industry for lead and phthalates, while recognizing that a broad industry exemption remains unlikely.
U.S. Advocacy
AEM’s U.S. advocacy frames 2026 as a politically sensitive election year, with increased attention on agriculture, rural voters, and equipment-policy issues. Key risks include ag and machine data governance, right-to-repair, dealer laws, workforce policy, equipment signage, and dairy innovation, while federal work focuses on infrastructure and Farm Bill opportunities.
Japan Chemical Regulations
Japan plans to implement COP12 Stockholm Convention decisions by designating MCCP, long-chain perfluoro carboxylic acids, their salts and related substances, and chlorpyrifos as Class I Specified Chemical Substances under the Chemical Substance Control Law. Construction equipment manufacturers should identify these substances in lubricants, oils, coatings, adhesives, sealants, firefighting agents, and treated fabrics, engage suppliers on alternatives, and prepare for expected 2026 rulemaking milestones.
South Korea RoHS Update
South Korea is expanding hazardous-substance restrictions and take-back/recycling obligations for electrical and electronic products in phases beginning in 2026 and 2028 to better align with EU RoHS II. Construction machinery remains excluded because it is already regulated separately, difficult to collect through general recycling systems, and typically recycled through specialized dismantling and scrap processes.
Stay tuned for Part 4 of AEM’s JTLM summary, set to be featured in the July 27 edition of the AEM Industry Advisor.
About the JTLM
The JTLM consists of various global trade associations (AEM from the United States, CCMA from China, CECE from the European Union, CMEIG from Australia, ICEMA from India, KOCEMA from Korea, and CEMA from Japan) presenting and exchanging information on current and ongoing legislative, compliance, and standards activities worldwide.
For more than three decades, members and staff from the aforementioned associations have gathered in-person to promote:
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Reduction of technical barriers to trade
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Harmonization of product-oriented legislation, regulations, and standards in areas such as safety, environment, health, and product quality, as well as testing and certification of products
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The development and announcement of clear, effective, and reasonable legislation, regulation, and standards
For addition information on AEM Safety & Product Leadership activities, contact AEM’s Jason Malcore at jmalcore@aem.org.
