Sustainability regulatory updates, the circular economy and the environment

 

EUROPE

EU Deforestation Regulation:

On the 23rd of December 2025, the European Union published Regulation (EU) 2025/2650, a targeted revision of the EU Deforestation Regulation (EUDR) that amends Regulation (EU) 2023/1115 to simplify certain obligations for operators and traders and to adjust key timelines for implementation.

Please note that achieving compliance requires time; therefore, organisations should not postpone their efforts. The additional time is intended to ensure a smooth transition and to allow for improvements to the IT systems used by operators, traders, and their representatives to submit electronic due diligence statements.

All businesses would be granted an additional year to comply with the new European Union regulations. Large operators and traders must comply with the regulation by 30 December 2026, while small operators—such as private individuals and micro or small enterprises—must comply by 30 June 2027.

The text enters into force on the 26^th of December 2025.

For further information, consult the European Commission website here.

At Eurofins Sustainability Services, we provide EUDR readiness: supplier mapping with cascading questionnaires and precise geolocation capture, deforestation risk assessment, targeted mitigation planning, and tailored reporting.

Start now to de‑risk compliance and avoid last‑minute bottlenecks: https://sustainabilityservices.eurofins.com/services/eudr-deforestation-impact-assessment/

EU Adopts New Regulation to Strengthen Toy Safety Across Europe

On the 12^th of December 2025, The European Union has officially adopted Regulation (EU) 2025/2509, a law aimed at ensuring a higher level of safety for toys and protecting children from potential hazards. The new regulation, published today in the Official Journal of the European Union, repeals the previous Directive 2009/48/EC and introduces stricter requirements for manufacturers, importers, and distributors.

The regulation addresses growing concerns about harmful chemicals, digital risks, and emerging technologies in toys. It introduces generic prohibitions on hazardous substances, including carcinogenic, mutagenic, and endocrine-disrupting chemicals, as well as PFAS and certain bisphenols. Manufacturers will now be required to conduct comprehensive safety assessments and comply with updated chemical limits to protect children’s health.

In addition to chemical safety, the regulation sets out essential safety requirements covering physical, mechanical, flammability, electrical, hygiene, and radioactivity hazards. It also tackles new challenges posed by digitally connected toys, requiring compliance with cybersecurity and privacy standards under related EU legislation.

A major innovation is the introduction of a Digital Product Passport (DPP) for toys, which will replace the traditional EU Declaration of Conformity. This passport will provide detailed compliance information accessible via a data carrier on the toy or its packaging, enhancing transparency for consumers and facilitating market surveillance and customs checks.

The regulation also strengthens obligations for economic operators and online marketplaces, ensuring that toys sold online meet EU safety standards. Market surveillance authorities will have enhanced powers to act against non-compliant products, and customs authorities will verify DPPs for imported toys.

Key dates:

• Entry into force: on 1^st of January 2026.
• Application: From 1 August 2030, with transitional provisions allowing toys compliant with the old directive until that date.
• Certain provisions, including those on conformity assessment bodies and digital product passports, apply from 1 January 2026.

The European Commission will provide guidance to SMEs and publish practical tools to help manufacturers adapt to the new requirements.

For full details, visit the official EUR-Lex page: Regulation (EU) 2025/2509.

 

EU Proposal Targets MCCPs as a persistent organic pollution

On the 21st of November 2025, the European Commission opened a European initiative which would add medium-chain chlorinated paraffins (MCCPs) to the list of persistent organic pollutants under Regulation (EU) 2019/1021.

What this means:

• MCCPs will be banned in substances, mixtures, and articles, with some temporary exemptions for specific uses (e.g., industrial or professional use, machinery, vehicles, medical devices, aerospace, defence).
• Manufacturers must ensure MCCPs are not present above 0.1% by weight as unintentional trace contaminants.
• The maximum duration of the exemptions should be five years, with the possibility to extend them for an additional period of five years, in accordance with the Convention.
• Manufacturers, suppliers and importers will need to update compliance processes and documentation accordingly and provide downstream users with information on the presence of certain linear C14-17 chloroalkanes in in their products in accordance with Article 31 of Regulation (EU) 1907/2006 in the Safety Data Sheet.

This will impact sectors using MCCPs in PVC cables, coatings, adhesives, and sealants, and will require substitution over time.

The feedback period for this draft is open until the 19th of December 2025, and the Commission adoption is planned for the second quarter of 2026.

For further details, please refer to the European Commission’s proposal here.

 

Simpler and smarter environmental legislation

On 10 December 2025, the European Commission released a comprehensive environmental simplification package, setting out targeted amendments across industrial emissions, circular economy legislation, waste law, environmental assessments, and spatial data systems. The aim is to reduce administrative burdens for businesses while maintaining environmental objectives:

 

Area	Key Measures	Intended Impact
Streamlined Environmental Assessments & Permitting	• Single points of contact for complex procedures • Increased digitalisation of assessments • Improved cross-border coordination • Measures to accelerate energy, digital and decarbonisation projects	Faster permitting, reduced delays, and improved investment deployment across Member States
Industrial Emissions & Reporting Simplification	• Environmental management systems allowed at company level • Simplified EMS content and removal of mandatory independent audits where equivalent systems exist • Exclusion of organic poultry farms from the Industrial Emissions Directive • Simplified livestock capacity calculations • Reduced reporting for livestock and aquaculture	Lower administrative burden while preserving environmental and health protections
Hazardous Substances in Products	• Repeal of the SCIP database obligation under the Waste Framework Directive • Functions progressively replaced by the Digital Product Passport and the One Substance One Assessment framework	Faster permitting, reduced delays, and improved investment deployment across Member States
Extended Producer Responsibility (EPR) Simplification	• Suspension of the obligation to appoint authorised representatives in every Member State for certain EPR schemes • Flexibility to maintain existing arrangements • Future limits on reporting frequency (max. once per year) and datasets • Planned digital one-stop shop for EPR registration and reporting	Reduced fragmentation and reporting burden, particularly benefiting SMEs
Geospatial Data (INSPIRE Directive)	• Alignment with the Open Data Directive • Simplified technical requirements and improved interoperability • Enhanced access and reuse of environmental and spatial datasets	Lower compliance costs and improved availability of geospatial data for monitoring, planning and digital innovation
Packaging and Packaging Waste Regulation (PPWR) – Implementation Support	• Commission guidance and FAQs on PFAS testing, application dates, labelling and reuse targets • Draft delegated act expected to exempt pallet wrappings and straps from the 100% reuse target • Additional flexibilities for hygiene- or food-safety-sensitive packaging • Simplified reporting through implementing measures	Smoother PPWR implementation while maintaining circular economy objectives
Forward-Looking Simplification Initiatives	• Targeted revision of REACH • Circular Economy Act (Q3 2026) to further digitalise and harmonise EPR and secondary materials markets • Evaluations of water, waste, chemicals and nature legislation	Reduced fragmentation and reporting burden, particularly benefiting SMEs

 

Simplified sustainability reporting and due diligence rules for businesses

The Council of the European Union and the European Parliament have reached a provisional agreement to simplify EU sustainability reporting and due diligence rules, significantly narrowing scope thresholds and extending implementation timelines to ease compliance burdens.

Scope reduction for EU companies

• In scope only if net turnover exceeds EUR 450 million and headcount is at least 1,000 employees (entity or consolidated level)

Scope for non-EU groups

• Reporting required where EU net turnover exceeds EUR 450 million
• Group must have an EU subsidiary or branch generating at least EUR 200 million in turnover

Application timeline

• Member States may exempt companies below the new thresholds for financial years 2025 and 2026
• Revised scope applies in full from financial year 2027

Revised ESRS

• New, simplified ESRS to be adopted within six months of CSRD entry into force

Value chain disclosures

• Introduction of “value chain caps” limiting information requests to entities with fewer than 1,000 employees
• Three-year transition period allowing the use of estimates where full data cannot be obtained

Assurance and implementation

• Limited assurance remains the applicable assurance level
• EU sustainability reporting assurance standards due by 1 July 2027

 

FRANCE

France Adopts New Decree to Ban PFAS in Consumer Products

On the 30th of December 2025, the French government published Decree No. 2025-1376, introducing strict measures to prevent risks associated with perfluoroalkyl and polyfluoroalkyl substances (PFAS).

The decree applies to a wide range of products, including cosmetics, textiles, footwear, and waterproofing agents. Under this regulation, the manufacture, import, export, and marketing of products containing PFAS will be prohibited as of 1 January 2026. A transitional period of 12 months is granted for the sale of existing stock produced prior to this date. The decree specifies residual concentration thresholds for PFAS as follows:

• 25 ppb for individual PFAS (excluding polymers)
• 250 ppb for the sum of PFAS (with prior degradation of precursors, excluding polymers)
• 50 ppm for total fluorine content (including polymers)

If the total fluorine measurement exceeds 50 mg F/kg, the manufacturer, importer, exporter, or producer must provide, upon request from the competent authorities, proof that the fluorine content originates from PFAS or non-PFAS substances.

Certain exemptions are allowed, notably for:

• Personal protective equipment (PPE) under EU Regulation 2016/425,
• Military and civil protection gear,
• Textiles and footwear incorporating at least 20% recycled material, where PFAS presence is limited to the recycled fraction.

This decree implements provisions of Law No. 2025-188, adopted earlier this year to protect public health and the environment from PFAS-related risks. The regulation aligns with EU standards and anticipates future technical updates under European chemical safety regulations. The Ministry of Ecological Transition emphasized that these measures aim to reduce PFAS exposure, which has been linked to environmental persistence and potential health hazards.

 

The table below summarises the most recent publications regarding sustainability, the circular economy, and the environment (non-exhaustive):

 

Entity	Date	Publication
China	29/12/2025	China’s Ministry of Ecology and Environment (MEE), together with the National Disease Control and Prevention Administration, announcement on the Release of the “Priority Controlled Chemicals List (Batch III)”. The inventory includes 23 types of chemical substances, among which are carcinogens such as 1,1,2,2-tetrachloroethane and tri(2,3-dibromopropyl) phosphate, endocrine disruptors like bisphenol A and di(2-ethylhexyl) phthalate, and persistent organic pollutants such as long-chain perfluoroalkyl substances, their salts, and related compounds. These substances are prevalent in industries including petrochemicals, plastics, rubber, pharmaceuticals, textiles, dyes, paint, pesticides, leather, and electroplating industries or sectors. Notably, certain PFAS, POPs that attract significant public concern but remain unlisted in the China Existing Chemical Substances Inventory—such as potassium perfluoropolyethoxysulfate (F-53B) and perfluorobutyl sulfonic acid (PFBS)—are excluded from the Inventory. Their production, use, and import must comply with the Environmental Management Registration Measures for New Chemical Substances.
EU Council	19/12/2025	The Council of the European Union and the European Parliament have reached a political agreement setting a binding EU climate target of at least a 90% reduction in net greenhouse gas emissions by 2040 compared with 1990 levels, marking a major milestone in the Union’s long-term climate framework. The agreement establishes the 2040 target as an intermediate step on the legally binding path to climate neutrality by 2050 under the European Climate Law, while confirming that emissions reductions will be achieved primarily within the EU, complemented by limited use of high-quality international credits under strict conditions. It also strengthens governance and monitoring provisions, requires the Commission to assess consistency of future EU legislation and policies with the 2040 target, and provides a clearer investment signal to industry and Member States to accelerate decarbonisation across energy, industry, transport, agriculture and buildings.
EU Commission	17/12/2025	In December 2025, the European Commission proposed a European Biotech Act that establishes a common EU framework to strengthen the Union’s biotechnology and biomanufacturing sectors, with a particular focus on health-related applications. The proposal aims to enhance EU competitiveness, innovation capacity and security of supply by streamlining regulatory pathways, improving coordination across authorities, and facilitating faster development, testing and market access for biotech products, while maintaining high standards of safety, quality and environmental protection. To achieve this, the Act introduces targeted amendments to existing EU legislation, including Regulations (EC) No 178/2002, (EC) No 1394/2007, (EU) No 536/2014, (EU) 2019/6, (EU) 2024/795 and (EU) 2024/1938, to reduce regulatory fragmentation, supporting scale-up and industrial deployment, and reinforcing the EU’s strategic autonomy in key biotechnologies.
EU Commission	15/12/2025	The European Commission has launched a public feedback process on an initiative introducing new battery labelling rules under the EU Batteries Regulation, aimed at improving transparency, sustainability and consumer information across the battery value chain. The initiative proposes harmonised labelling requirements to provide clearer information on battery performance, capacity, durability, carbon footprint, recyclability and safety, including the use of digital tools such as QR codes linked to the battery passport. The new rules are intended to support informed consumer choices, facilitate repair, reuse and recycling, and strengthen enforcement and market surveillance, while ensuring consistency with the EU’s circular economy and climate objectives
Connecticut – US	12/12/2025	Connecticut DEEP (Department of Energy & Environmental protection) has approved specific phrases that manufacturers must use when labelling products containing intentionally added PFAS. Beginning July 1, 2026, certain product categories (e.g., apparel, cookware, cosmetics, rugs, dental floss, juvenile products, upholstery, textiles, ski wax) cannot be sold or distributed in the state unless they include a clear label indicating PFAS content. Approved wording includes: “Contains PFAS” “Made with PFAS” “Made with intentionally added PFAS” “This product contains PFAS chemicals” Labels must be visible before purchase and durable for the product’s useful life. Manufacturers must also provide DEEP with advance notice detailing PFAS identity, amount, purpose of use, and product information.
EU Commission	12/12/2025	On 12 December 2025, the European Commission published Regulation (EU) 2025/2457, advancing the implementation of the EU Chemicals Strategy for Sustainability through targeted amendments to Regulations (EC) No 178/2002, (EC) No 401/2009, (EU) 2017/745 and (EU) 2019/1021. The Regulation reallocates scientific and technical tasks among Union agencies and strengthens inter-agency cooperation to operationalise the “one substance, one assessment” principle. By reducing duplication, improving data sharing and aligning assessment procedures across chemicals, food safety, medical devices and persistent organic pollutants frameworks, the measure aims to deliver more coherent, efficient and timely risk assessments. These changes support a more integrated EU chemicals governance system, enhancing regulatory predictability while reinforcing protection of human health and the environment in line with the objectives of the Chemicals Strategy for Sustainability.
EU Commission	12/12/2025	On 12 December 2025, the European Commission published Directive (EU) 2025/2456, amending the EU chemicals governance framework to strengthen coordination, efficiency and scientific coherence in line with the EU Chemicals Strategy for Sustainability. The Directive focuses on improving cooperation and task allocation among Union agencies, notably in areas where chemical risk assessments intersect with food safety, consumer products, medical devices and persistent organic pollutants. Key objectives include reinforcing the “one substance, one assessment” principle, reducing duplication of scientific work, and ensuring more consistent and timely risk assessments across EU legislation. To achieve this, the Directive clarifies roles, information-sharing obligations and coordination mechanisms between agencies, while maintaining high levels of protection for human health and the environment.
EU Commission	12/12/2025	On 12 December 2025, the European Commission published Regulation (EU) 2025/2455, introducing targeted amendments to the EU Classification, Labelling and Packaging (CLP) framework that reinforce the objectives of the Chemicals Strategy for Sustainability by improving hazard communication, regulatory coherence and environmental and health protection across the internal market. The Regulation updates and clarifies classification and labelling rules in line with scientific and technical progress, strengthening the identification and communication of hazardous properties of substances and mixtures to support safer chemical design, substitution of harmful substances and informed downstream use. By aligning CLP procedures more closely with related EU chemicals legislation and improving legal certainty for manufacturers, importers and downstream users, the amendments contribute to more effective risk management, reduced exposure to hazardous chemicals and a more sustainable chemicals lifecycle, while maintaining a high level of protection for human health and the environment.
EU Commission	12/12/2025	On 12 December 2025, the European Commission published an Impact Assessment Report accompanying the proposal to amend Regulation (EU) 2023/956, which established the Carbon Border Adjustment Mechanism (CBAM). The report analyses the rationale and expected impacts of extending the scope of CBAM to certain downstream goods and introducing anti-circumvention measures, with the objective of preventing carbon leakage through the shifting of emissions to later stages of the value chain or through practices designed to bypass the mechanism. It assesses environmental, economic and administrative impacts, concluding that the proposed changes would strengthen the effectiveness and environmental integrity of CBAM, ensure a level playing field between EU and non-EU producers, and support the EU’s climate objectives while limiting unnecessary burdens on operators through targeted and proportionate design choices.
ECHA	12/12/2025	The European Chemicals Agency has published guidance to support stakeholders responding to the Socio-Economic Analysis Committee (SEAC) consultation on the proposed EU restriction of per- and polyfluoroalkyl substances (PFAS). The document sets out how companies, authorities and other stakeholders should submit evidence on the socio-economic impacts of the proposed restriction, including detailed information on specific uses, the availability and feasibility of alternatives, substitution timelines, costs, benefits and broader impacts on society, health and the environment. The guidance emphasises the importance of providing robust, use-specific and, where possible, quantitative data to enable SEAC to assess the proportionality and effectiveness of the proposed PFAS restriction under the REACH framework.
EU Commission	12/12/2025	The European Commission has proposed a Commission Delegated Decision supplementing European Union Regulation (EU) 2025/40 on packaging and packaging waste, introducing a targeted exemption from reuse obligations for pallet wrappings and straps used in transport packaging. Under the Packaging and Packaging Waste Regulation, economic operators would otherwise be required from 1 January 2030 to ensure 100% reuse of these formats for transport within the same company, between linked or partner enterprises, or within the same Member State; however, based on economic and technical evidence, the Commission concludes that mandatory full reuse would lead to disproportionate adaptation costs, including significant investments in new automated packaging lines, IT systems and staff training, and could disrupt supply chains. The delegated act therefore exempts economic operators using pallet wrappings and straps for stabilisation and protection of goods on pallets from the 100% reuse targets while leaving intact the overall 40% reuse target and will apply from 1 January 2030 following its entry into force after publication in the Official Journal.
EU Commission	10/12/2025	The European Commission has launched a public feedback process on a draft delegated act under the Packaging and Packaging Waste Regulation (PPWR) that proposes targeted exemptions from the reuse obligations for certain plastic wrappings and straps. According to the initiative, the delegated act aims to clarify the application of the PPWR reuse requirements by exempting specific types of plastic transport packaging where reuse is considered impractical or would not deliver clear environmental benefits, taking into account hygiene, safety and operational constraints. The measure is intended to support legal certainty and proportional implementation of the PPWR, while maintaining its overall objectives of waste prevention, circularity and reduced environmental impact, and stakeholder feedback is invited as part of the Commission’s better regulation process before the act is finalised.
EU Commission	10/12/2025	The European Commission has launched a public feedback initiative on draft measures that would prohibit the manufacture, import and export of mercury switches and relays in the EU, aligning Union law with international commitments under the Minamata Convention on Mercury. The initiative proposes to tighten existing restrictions by extending bans to additional uses and transactions, with the objective of further reducing mercury emissions and exposure risks to human health and the environment. By closing remaining regulatory gaps and ensuring consistent application across the internal market, the proposed measures are intended to support the EU’s chemicals and zero-pollution objectives while providing legal clarity for manufacturers and traders, and stakeholder feedback is invited as part of the Commission’s better regulation process before the measures are finalised.
EU Commission	10/12/2025	On December 2025, the European Commission presented, a legislative proposal amending EU waste legislation to temporarily suspend the application of rules requiring the appointment of authorised representatives for certain extended producer responsibility (EPR) schemes, including those for waste, waste electrical and electronic equipment (WEEE), and single-use plastic waste. The proposal responds to concerns about administrative burden and fragmentation faced by producers operating cross-border, particularly SMEs, by allowing producers to comply with EPR obligations without having to appoint an authorised representative in each Member State during the suspension period. The measure is intended as an interim simplification step, pending more comprehensive harmonisation and digitalisation of EPR systems at EU level, while maintaining the core objectives of waste management, producer responsibility and environmental protection.
EU Council	09/12/2025	The Council of the European Union and the European Parliament have reached a provisional agreement to simplify EU sustainability reporting and due diligence rules, significantly narrowing scope thresholds and extending implementation timelines to ease compliance burdens; under the deal, CSRD sustainability reporting will apply only to companies with more than 1,000 employees and net annual turnover above €450 million, including non-EU companies meeting the same EU turnover threshold, while CSDDD due-diligence obligations will be limited to the largest companies with more than 5,000 employees and over €1.5 billion in net turnover, with sector-specific standards becoming voluntary and reporting content streamlined. The agreement also postpones transposition and application deadlines, giving Member States and companies additional time to prepare: CSRD application for in-scope companies is deferred, and the deadline for transposing the CSDDD is extended, with obligations applying at a later stage than originally planned, reflecting the co-legislators’ objective of boosting EU competitiveness while maintaining core sustainability safeguards.
EU Council	08/12/2025	The Council of the European Union has formally approved the new Detergents and Surfactants Regulation, updating the EU framework governing the placing on the market, composition, labelling and biodegradability of detergents and surfactants to better protect consumers and the environment. The regulation modernises existing rules by strengthening requirements on ingredient transparency and digital labelling, tightening controls on substances of concern, enhancing biodegradability standards for surfactants, and aligning enforcement and market surveillance across Member States, while also simplifying compliance obligations for businesses through clearer and more harmonised provisions.
EU Commission	08/12/2025	The European Union has adopted Regulation (EU) 2025/2481, establishing updated ecodesign requirements for fans with an electric input power between 125 W and 500 kW, with the objective of improving energy efficiency and reducing environmental impacts over the product lifecycle. The regulation sets minimum energy efficiency requirements, updated measurement and calculation methods, and enhanced product information and technical documentation obligations for manufacturers, importers and authorised representatives, while also introducing resource efficiency provisions to support durability, reparability and recyclability. It is intended to deliver energy savings, lower operating costs and reduced greenhouse gas emissions through more efficient fan technologies placed on the EU market.
European Financial Reporting Advisory EFRAG	03/12/2025	The European Financial Reporting Advisory Group (EFRAG) has published draft simplified European Sustainability Reporting Standards (ESRS) for consultation, aiming to reduce reporting complexity while preserving the core objectives of the EU sustainability reporting framework. The draft introduces a more proportionate and streamlined approach, with fewer mandatory data points, clearer materiality-based disclosures and simplified narrative and metric requirements, particularly designed to ease the reporting burden for companies newly in scope of sustainability reporting obligations. By focusing on the most decision-useful environmental, social and governance information and improving usability and consistency, the simplified ESRS are intended to support effective sustainability transparency while enhancing feasibility, comparability and cost-efficiency for reporting entities across the EU.
EU Commission	01/12/2025	EU employment ministers have agreed the Council’s position on updated rules to better protect workers from exposure to hazardous chemicals at work, advancing the sixth revision of the Carcinogens, Mutagens and Reprotoxic Substances Directive; the Council position strengthens worker protection by setting new occupational exposure limits for cobalt and its inorganic compounds, polycyclic aromatic hydrocarbons (PAHs) and 1,4-dioxane, adding welding fumes to the list of carcinogenic processes, and introducing an exposure limit for isoprene, while also updating definitions and recitals to reflect scientific developments and the health risks associated with these substances, to prevent thousands of occupational disease cases over the coming decades and pave the way for negotiations with the European Parliament once it adopts its position.
GOV.UK	01/12/2025	On December 2025, the United Kingdom published its Environmental Improvement Plan 2025, setting out priority actions to deliver the environmental objectives of the Environment Act. Within the Plan, Commitment 40 focuses on UK REACH, reaffirming the government’s commitment to maintain a robust domestic chemicals regulatory framework by improving the quality and availability of chemicals data, strengthening evaluation and risk-management processes, and ensuring that restrictions and other regulatory measures protect human health and the environment while remaining proportionate and supportive of innovation. Commitment 41 addresses PFAS, outlining a dedicated PFAS Action Plan aimed at building a stronger evidence base, enhancing environmental monitoring, and developing appropriate regulatory and risk-management options to reduce emissions and exposure to these persistent substances, in line with a precautionary and long-term approach to managing chemicals of concern.
European Parliament	December 2025	A recent European Parliament Think Tank study, examines the role of per- and polyfluoroalkyl substances (PFAS) as key enablers of competitiveness in European industry. The analysis highlights how the unique functional properties of PFAS—such as chemical resistance, thermal stability and durability—support critical applications in sectors including clean technologies, medical devices, electronics, aerospace and advanced manufacturing. At the same time, the study underlines the policy challenge of balancing these industrial benefits with increasing environmental and health concerns, stressing the importance of a proportionate and evidence-based regulatory approach that preserves innovation and strategic industrial capacity while promoting substitution and risk reduction where feasible.
Joint Research Centre	28/11/2025	The Joint Research Centre has published a technical report setting out testing conditions for kitchenware articles intended to come into contact with foodstuffs, providing scientific guidance to support consistent safety assessment across the EU. The report defines harmonised test parameters—such as simulants, temperatures, contact times and migration conditions—designed to better reflect real-life use of kitchenware materials and articles. By clarifying and standardising testing approaches, the guidance aims to improve the reliability and comparability of migration test results, support enforcement of food contact materials legislation, and ensure a high level of consumer health protection while offering greater legal certainty for manufacturers and testing laboratories.
EU Commission	27/11/2025	The European Commission has adopted Communication, setting out a renewed strategic approach to advance a circular, regenerative and competitive EU bioeconomy, positioning it as a key driver of sustainability, industrial competitiveness and strategic autonomy; the Communication outlines a framework to better mobilise renewable biological resources across sectors while respecting ecological limits, with a focus on scaling up innovation and market deployment of bio-based solutions, strengthening lead markets, improving coherence of policies and regulation, supporting regional and rural development, and enhancing global cooperation, with the overall objective of contributing to climate neutrality, resource efficiency, resilience of value chains and high-quality jobs across the European Union.
Michigan – US	27/11/2025	The State of Michigan has announced plans to ban the sale and use of coal tar–based pavement sealants, marking a significant environmental reform aimed at reducing polycyclic aromatic hydrocarbon (PAH) pollution in waterways and urban environments; the measure, led by the Department of Environment, Great Lakes, and Energy (EGLE), responds to scientific evidence linking coal tar sealants to elevated PAH concentrations in sediments, surface waters and aquatic life, and is intended to protect public health, ecosystems and drinking water sources, while encouraging the use of safer alternative sealants as Michigan advances broader efforts to address toxic pollution and improve environmental quality statewide.
World Trade Organization	27/11/2025	According to a notification submitted by the European Union to the World Trade Organization under the Technical Barriers to Trade framework, the European Commission has proposed a draft adaptation to technical progress of the CLP Regulation (Regulation (EC) No 1272/2008) that would update Annex VI by introducing new or revised harmonised classification and labelling entries for 48 chemical substances. The proposal reflects the outcome of scientific evaluations carried out at EU level and aims to ensure that hazard classifications remain aligned with the latest scientific and technical knowledge, thereby strengthening the protection of human health and the environment while preserving the proper functioning of the internal market. The draft measure, notified for comments in line with WTO transparency obligations, would require affected substances to be classified and labelled in accordance with the updated harmonised entries once adopted, with downstream implications for manufacturers, importers and users of chemicals placed on the EU market.
EU Commission	26/11/2025	The European Union has adopted Regulation (EU) 2025/2365, establishing the first EU-wide binding framework to prevent plastic pellet losses across the entire supply chain in order to reduce microplastic pollution, by imposing obligations on economic operators, EU and non-EU carriers, and maritime actors involved in the production, handling, storage, cleaning and transport of plastic pellets; the Regulation introduces mandatory risk management plans, spill prevention, containment and clean-up measures, staff training, record-keeping and reporting requirements, with differentiated obligations based on enterprise size and volume thresholds, alongside certification or self-declaration mechanisms, public transparency obligations and enhanced enforcement powers for national authorities, including inspections, penalties and compensation rights; specific rules are also laid down for the transport of plastic pellets by sea, while phased application dates allow operators time to adapt, with the Regulation applying fully from 17 December 2027 and earlier provisions entering into force from December 2025, reflecting the EU’s objective of achieving zero plastic pellet losses and contributing to the broader target of reducing microplastic pollution by 30% by 2030.
ECHA	26/11/2025	The European Chemicals Agency (ECHA) has announced that companies subject to the EU microplastics restriction can now begin submitting their annual reports on microplastics emissions via the REACH-IT system, with the first reports due by 31 May 2026 covering estimated emissions for the calendar year 2025; the reporting obligation applies to manufacturers, importers and downstream users of synthetic polymer microparticles (SPMs) for uses exempted from the EU-wide ban (including certain veterinary and human medicines, food additives, in vitro diagnostic devices and industrial site uses), and companies must prepare their reports in IUCLID format using updated software tools supported by ECHA, with guidelines, manuals and tutorials available to help ensure standardised and transparent data collection for monitoring emissions and supporting future policy evaluation.
Netherlands	26/11/2025	The Netherlands has amended its national legislation on food contact materials through an update to the Warenwetregeling verpakkingen en gebruiksartikelen, to incorporate additional substances into Part A of the annex following positive safety assessments by the Dutch food contact materials expert committee (NCbvv) coordinated by RIVM. The amendment clarifies and, where relevant, expands the authorised conditions of use for certain substances in food contact applications, enabling their use provided the specified restrictions are respected.
South Korea	24/11/2025	On 24 November 2025, South Korea’s Ministry of Environment published a partial amendment to the Guidelines on Separate Collection of Recyclable Resources, an administrative guideline that, while not legally binding, is applied nationwide by municipalities and operators responsible for waste collection and recycling; the amended guideline updates operational criteria for the classification, separation and collection of recyclable waste, with a particular focus on packaging materials, clarifying requirements for material separability, treatment of composite and multi-material packaging, and the sorting of plastics by material type; it specifies conditions under which packaging composed of mixed materials may be considered recyclable only if its components can be easily separated by hand, confirms differentiated treatment for plastics such as PET based on characteristics affecting recyclability, excludes certain materials such as PVC from recyclable streams, strengthens preparation and sorting instructions for end users, and clarifies that small non-packaging plastic items placed in recycling streams are treated as contaminants rather than recyclable materials.
EU Commission	21/11/2025	The European Commission published Commission Notice, establishing guidelines for businesses on the application of the EU General Product Safety Regulation (GPSR), which clarifies how companies must interpret and implement their legal obligations under the GPSR to ensure that only safe products are made available on the EU market; the notice covers the scope of the GPSR, definitions of safe products, responsibilities of economic operators (including manufacturers, authorised representatives, importers, distributors and online marketplace providers), risk assessment and technical documentation requirements, product information and labelling, traceability, steps to take after placing products on the market (such as corrective actions and reporting accidents), use of the Safety Business Gateway and Safety Gate Portal for notifications, and best practices to help businesses comply with the GPSR and contribute to a high level of consumer protection in the EU Single Market.
EU Commission	20/11/2025	In a strategic step to deepen economic ties and sustainable development cooperation, the European Commission and the Government of South Africa have agreed on a Clean Trade and Investment Partnership, formally signed during the margins of the G20 Leaders’ meeting on 20 November 2025, aimed at enhancing cooperation on trade, investment, and climate-friendly economic growth; alongside this partnership, the two sides also concluded a new cooperation agreement on minerals and metals, which will support responsible supply chains and green industrial transition efforts, reflecting shared priorities on clean trade, investment and sustainable value chains between the EU and South Africa
International Chamber of Commerce (ICC)	20/11/2025	The International Chamber of Commerce (ICC) has released a Practical Guide on Competition Law and Sustainability Agreements (November 2025), offering high-level direction for businesses on how competition and antitrust laws apply to sustainability cooperation initiatives in key jurisdictions including the European Union, United Kingdom and United States, by outlining which forms of cooperation between companies are unlikely to infringe competition law, criteria for permissible sustainability agreements, how exemptions or safe harbours may apply in some jurisdictions, and highlighting that sharing commercially sensitive information between competitors requires particular care and legal consideration to avoid collusion risks, while also calling on authorities to provide greater legal clarity to unlock responsible sustainability collaborations at scale
EU Commission	20/11/2025	The European Commission has published the long-awaited SFDR 2.0, proposing a fundamental overhaul of the EU sustainable finance disclosure framework by replacing the existing disclosure-based approach with a product categorisation regime built around three new categories—Transition (Article 7), ESG Basics (Article 8) and Sustainability (Article 9)—each anchored by a 70% investment threshold and mandatory exclusions; the proposal introduces clearer criteria for qualifying investments, formally recognises impact investing, allows for phase-in periods where justified, and sets out differentiated disclosure obligations by category while significantly simplifying pre-contractual and website disclosures; entity-level principal adverse impact and remuneration disclosures are removed, sustainability risk disclosures remain, and products that do not fall within any category face tighter limits on sustainability references; there is no automatic grandfathering, though closed products may opt out, and the scope of SFDR is narrowed by excluding portfolio managers and financial advisers, alongside related changes to PRIIPs requiring sustainability categorisation and objectives to be disclosed in KIIDs.
EU Commission	19/11/2025	The European Commission published a Communication on the “2030 Consumer Agenda and action plan for consumers in the single market – A new impulse for consumer protection, competitiveness and sustainable growth,” outlining EU priorities and planned actions through 2030 to strengthen consumer rights, enhance market competitiveness, and support sustainable economic growth across the internal market; the agenda identifies key areas for reform and implementation, including measures to improve enforcement of consumer protection rules, ensure safer and more transparent products and services, address emerging challenges linked to digitalisation and green transition, and reinforce consumer confidence and empowerment in cross-border transactions within the EU single market.
TRIS-Belguim	19/11/2025	The European Commission received TRIS notification from Belgium concerning a draft Cooperation Agreement amending the Cooperation Agreement of 4 November 2008 on the prevention and management of packaging waste, an instrument with statutory force applicable across the entire Belgian territory, which updates national rules on extended producer responsibility for packaging waste to align them with Regulation (EU) 2025/40, replacing the former Packaging Directive; the notification explains that the amendments are primarily intended to ensure consistency with EU law and do not introduce new technical regulations, either de jure or de facto, while also adjusting provisions previously introduced under a notified framework for extended producer responsibility for certain waste streams and litter, including clarifications related to packaging waste, litter obligations and sub-streams linked to the implementation and extension of rules connected to single-use plastics, with the notification submitted as a precautionary and consistency measure and limited to formal adjustments without additional substantive changes.
Taiwan	17/11/2025	On 17 November 2025, Taiwan’s Ministry of Environment launched a public consultation on a draft amendment to the appendix of the “Types and Limits of Health-Hazardous Substances Prohibited from Injection into Groundwater Bodies,” proposing to add perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) to the list of substances that must not be detected in groundwater, with the comment period open until 16 January 2026; this amendment aims to enhance the regulatory framework protecting groundwater resources by explicitly banning these two per- and polyfluoroalkyl substances from injection into groundwater bodies and solicits stakeholder feedback on the proposed changes during the consultation period.
France	13/11/2025	The French Government adopted an order on 13 November 2025 granting formal approval to Renault SAS as an individual system operator within the extended producer responsibility (EPR) scheme for batteries, under France’s environmental legal framework; this approval allows Renault to fulfil its statutory EPR obligations for managing waste from electric vehicle batteries by operating an accredited individual system until 31 December 2027, in accordance with the applicable provisions of the French Environment Code and the battery regulation framework, and the order enters into force upon notification to the company.
UN Global Compact Spain	11/11/2025	The UN Global Compact Spain (Pacto Mundial) has published a Sustainability Guide for Fashion Companies aimed at supporting the fashion sector in aligning with emerging European regulations on traceability, ecodesign and producer responsibility by offering a “Hoja de ruta en sostenibilidad” that helps companies identify and address their environmental, social and governance (ESG) impacts, risks and opportunities; the guide highlights the fashion industry’s significant economic footprint in Spain and Europe and proposes strategic actions to mitigate high water consumption, reliance on non-renewable resources and textile waste, including decarbonising supply chains, investing in clean technologies, fostering circularity and sustainable materials, ensuring decent labour conditions and human rights due diligence, integrating sustainability into corporate governance and reporting, and building sectoral collaboration, with the overall aim of turning sustainability into a competitive advantage that enhances innovation, efficiency and long-term industry performance.
U.S. Environmental protection Agency (EPA)	11/11/2025	In November 2025, the U.S. Environmental Protection Agency (EPA) published changes to the proposed rule to revise the PFAS reporting requirements under Section 8(a)(7) of the Toxic Substances Control Act (TSCA), seeking to reduce industry burden by amending the original 2023 reporting rule’s scope and submission deadlines; the proposal would incorporate new exemptions for certain PFAS reporting obligations—such as for **imported articles, low-concentration PFAS (below specific thresholds), byproducts, impurities and non-isolated intermediates, and small quantities used solely for research and development—**with public comments requested, adjust the data submission window in line with the effective date of the final revisions, and estimate total industry burden reductions that reflect significant compliance cost savings compared to the original rule requirements.
Washington -US	11/11/2025	Washington State has proposed amendments to Chapter 173-334 WAC to expand and clarify existing restrictions on per- and polyfluoroalkyl substances (PFAS) in consumer products, updating definitions, compliance pathways and enforcement provisions under the state’s safer products framework; the draft amendment refines product scope and regulatory terminology, clarifies how manufacturers must demonstrate that safer alternatives are available or that exemptions apply, strengthens reporting and certification obligations, and aligns implementation timelines and administrative processes with the underlying statutory requirements, intending to improve legal certainty, close regulatory gaps and supporting more effective phase-out of PFAS in regulated consumer goods placed on the Washington market.
EU Commission	13/10/2025	The European Commission has published Staff Working Document, an impact assessment report accompanying a proposed Commission Regulation under the Ecodesign Directive that would set updated ecodesign requirements for external power supplies, wireless chargers, wireless charging pads, battery chargers for portable batteries of general use and USB Type-C cables, while repealing Commission Regulation (EU) 2019/1782; the report assesses the need for EU action, policy objectives and options, and the expected economic, environmental and social impacts of extending the scope of ecodesign requirements, strengthening energy efficiency thresholds (including efficiency at low load and no-load conditions), introducing durability and interoperability requirements, and addressing standby power consumption for wireless charging, concluding that the preferred policy option would contribute to the EU’s energy efficiency, climate and circular economy objectives by reducing energy losses during use, increasing interoperability and product longevity, and delivering net benefits for consumers and society over time.
EU Council	11/12/2025	From a sustainability perspective, the Council of the European Union has formally approved targeted amendments to the InvestEU Programme aimed at simplifying access to EU financing while reinforcing support for the green transition and long-term competitiveness. The changes streamline procedures, reduce administrative complexity and enhance flexibility in the use of EU guarantees, with the objective of accelerating investments in priority areas such as climate action, environmental protection, sustainable infrastructure, clean energy, circular economy and innovation. By making it easier for public and private actors to mobilise funding for sustainable projects and by improving the efficiency of EU financial instruments, the revised InvestEU framework is intended to help scale up green investments, crowd in private capital and support the delivery of the EU’s climate and sustainability objectives alongside economic growth.

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