Sustainability regulatory updates, the circular economy and the environment

 

Europe

European Commission published EUDR supply chain infographics (3rd edition): “Understanding your position in beef, cocoa, coffee, palm oil, rubber, soy and wood supply chains”

The European Commission, via the Publications Office of the European Union, has released the “EUDR supply chain infographics (3rd edition)”, which explains how the Regulation (EU) 2023/1115 (EUDR) applies across supply chains for relevant commodities; the publication focuses on beef, cocoa, coffee, palm oil, rubber, soy and wood, and is intended to help stakeholders understand their position in these supply chains in relation to the Regulation; it outlines that the EUDR introduces obligations for operators and traders when placing or making available these commodities and derived products on the Union market, as well as when exporting them from the Union; the infographics clarify supply chain roles and responsibilities under the Regulation, supporting the practical understanding of how the EUDR requirements apply across different actors involved in the production, trade, and distribution of the covered commodities it also includes all the amendments from December 2025. To download, please click here.

 

European Commission published PPWR FAQ & Guidance

On 30 March 2026, the EU Commission published the PPWR FAQ and Guidance, addressing topics such as:

How to enforce PFAS limits in food contact packaging: The Commission provides a specific three-step testing methodology

1. Total Fluorine (TF) quantification (step 1): If TF is below 50 mg/kg (16), the sample could be considered compliant.
2. If TF is above 50 mg/kg, methods such as pyrolysis-GC/MS can be used to confirm whether the fluorine is organic (PFAS) or inorganic in step 2. If the organic fluorine is below 50 mg/kg, the sample could be considered compliant.
3. Direct TOP (total oxidizable precursors) analysis is recommended to check compliance with the 25 µg/kg (17) and 250 µg/kg concentration limit in step 3.

Recyclability: The current EN 13430:2004 standard applies until the entry into force of the delegated acts (planned for 2028 + 24 months).

Compostable Packaging: Until new harmonised EU standards are adopted, the existing standard EN 13432 for industrial composting may be used as guidance.

 

JRC – Methodology for defining data requirements for the Digital Product Passport under the ESPR framework

On 19 March 2026 The EU published the methodology that will shape how Digital Product Passport data requirements are set for every product group, textiles included.

The JRC’s new report doesn’t define what goes in the Digital Product Passport (DPP). It defines how regulators will decide what goes in the DPP.

The report introduces a practical, step by step approach for defining and prioritizing DPP data requirements. It builds on existing ESPR work by focusing specifically on the semantic definition of information needs and by examining current industry data collection and data sharing practices across product value chains. The methodology translates policy objectives and uses cases into structured data categories, distinguishing essential, strongly recommended, and voluntary elements. These distinctions are based on a transparent assessment of value, effort, and feasibility grounded in real world practices.

While technical aspects of the DPP system are considered, this is limited to areas necessary for decisions on data access rights, governance, and granularity. Broader system architecture and implementation details remain outside the scope. Although the methodology is designed primarily to support ESPR delegated acts and impact assessments, its modular structure allows it to be applied beyond the ESPR framework when supported by equivalent contextual and feasibility analyses. This provides policymakers with a consistent and scalable tool for designing coherent, enforceable, and future proof DPPs.

 

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

 

 

Entity	Date	Publication
China	12/03/2025	On 12 March 2026, the National People’s Congress adopted the Ecological and Environmental Code marking China’s second formal legal code following the 2020 Civil Code, consolidating and updating a broad body of environmental legislation through a “moderate codification” approach that fully incorporates ten major environmental laws while maintaining others separately with referenced or streamlined provisions, and introducing for the first time at statutory level national regulatory frameworks for chemical substances, non-ionizing radiation and light pollution, including lifecycle controls, designation of priority controlled new chemical pollutants, pre-marketing registration requirements for new chemical substances, clarified emission standards and tiered regulation for radiation-emitting facilities, and enforceable limits on light pollution, while also establishing a statutory framework for climate governance by embedding carbon peaking and carbon neutrality targets into national planning, authorising controls over both total and intensity of carbon emissions, mandating carbon accounting, product carbon footprint management and monitoring of carbon sinks, and elevating the national emissions trading system into law with strengthened requirements for emissions data verification and allowance surrender, with the Code entering into force on 15 August 2026.
European Parliament	19/03/2025	The European Parliament, through its Policy Department for Transformation, Innovation and Health, published on 19 March 2026 a study assessing the European Commission’s proposal for the 2028–2034 multiannual financial framework (MFF) from a climate and environmental perspective; the study examines proposed changes to the EU spending architecture, including climate and biodiversity targets and tracking methodologies, and evaluates how these may affect climate mainstreaming, biodiversity integration, and performance monitoring; it also analyses potential implications of the proposed framework based on lessons learned from the 2014–2020 and 2021–2027 MFF periods; the document was prepared at the request of the Committee on the Environment, Climate and Food Safety (ENVI) and is intended to support parliamentary scrutiny of the Commission’s MFF proposals.
US	19/03/2026	On 19 March 2026, a statement was recorded in the Congressional Record (Vol. 172, No. 50, p. S1370) and published by the United Staes Congress referring to the “Forever Chemical Regulation and Accountability Act of 2026″ (S. 4153 / H.R. 8016) , in which remarks were made concerning legislative action addressing per- and polyfluoroalkyl substances (PFAS), including references to the phaseout of such substances and their regulation, as set out in the Congressional Record, reflecting the introduction and discussion of the proposed act within the Senate proceedings.
EU Commission	20/03/2026	The European Commission has published Implementing Regulation (EU) 2026/718, laying down rules for the application of Regulation (EU) 2024/1735 of the European Parliament and of the Council as regards minimum environmental sustainability requirements for public procurement procedures involving certain net-zero technologies; the Regulation was published in the Official Journal of the”Forever Chemical Regulation and Accountability Act of 2026″ (S. 4153 / H.R. 8016) he United  European Union on 23 March 2026 and sets out the minimum environmental sustainability requirements that contracting authorities must apply when procuring the covered net-zero technologies, including the criteria and conditions to be used in procurement procedures and the related obligations for economic operators; the Regulation enters into force on 12 April 2026 (the twentieth day following publication) and is binding in its entirety and directly applicable in all Member States.
ECHA	25/03/2026	The European Chemicals Agency (ECHA) announced that it will launch a consultation on the draft opinion of its Committee for Socio-Economic Analysis (SEAC) regarding the proposed restriction of per- and polyfluoroalkyl substances (PFAS) under the REACH Regulation; the consultation is scheduled to start on 18 June 2026 and will run for 60 days, allowing stakeholders to provide comments specifically on the socio-economic aspects of the proposed restriction; this follows the earlier opinion adopted by the Committee for Risk Assessment (RAC), and forms part of the REACH restriction procedure for PFAS, which are widely used chemicals of concern due to their persistence; the consultation aims to gather additional evidence to support SEAC in finalising its opinion, which will contribute to the European Commission’s decision-making on a potential EU-wide restriction.
ECHA	26/03/2026	The European Chemicals Agency announced that it supports the proposed EU restriction on per- and polyfluoroalkyl substances (PFAS) under the REACH Regulation, indicating that the restriction should proceed with targeted derogations for specific uses where alternatives are not yet available, based on the evaluation of scientific and technical information by its committees, while highlighting the objective of reducing PFAS emissions and exposure in the European Union and noting that the committees’ opinions will inform the European Commission’s decision-making process on the proposed restriction.
Legifrance	28/03/2026	On 28 March 2026 Legifrance published the Order of 25 March 2026 amending the Order of 23 November 2022 establishing the specifications for eco-organisations and individual systems in the extended producer responsibility sector for textiles, footwear and household linen (TLC), updating the requirements applicable to eco-organisations and approved individual systems operating within this sector, including the specifications governing their approval, organisation, and operational obligations under the extended producer responsibility framework.
EU Commission	30/03/2026	The European Commission has opened a feedback initiative on new reporting obligations for used textiles and textile waste under the 2025 amendment of the Waste Framework Directive; the initiative sets out plans to introduce harmonised reporting requirements for Member States concerning the separate collection, reuse, recycling and treatment of textile waste, in order to improve data quality and comparability across the European Union; it aims to support the implementation of extended producer responsibility schemes for textiles and to monitor progress towards waste reduction and circular economy objectives. The adoption of the proposal is planned for the first quarter of 2027.
EU Commission	31/03/2026	On 31 March 2026, European Parliament Resolution C/2026/1435 was published in the Official Journal of the European Union, concerning Commission Implementing Regulation (EU) 2025/1093 of 22 May 2025 under Regulation (EU) 2023/1115 on deforestation-free products (EUDR), in which the European Parliament considers that the Implementing Regulation exceeds the Commission’s implementing powers and calls on the European Commission to repeal it, highlighting concerns regarding the methodology used for the risk classification of countries, including the use of outdated data, lack of transparency, insufficient consideration of forest degradation and regional differences, and the absence of mechanisms for regular reassessment, and urging revisions to ensure updated data, clearer methodologies, regular review procedures, and greater engagement with countries producing relevant commodities and stakeholders.
World Trade Organization / Italy	01/04/2026	On 1 April 2026, WTO notification G/TBT/N/ITA/391 was submitted by Italy to the World Trade Organization Committee on Technical Barriers to Trade, concerning a proposal for a technical regulation introducing biodegradability and compostability requirements for certain single-use plastic packaging falling under HS code 3923 and ICS code 55.020, notified by the Ministry for Enterprises and Made in Italy, which amends Legislative Decree No. 152 of 3 April 2006 by inserting new provisions requiring specific packaging types to meet biodegradability and compostability criteria, establishing compliance obligations with legislation on food-contact materials and waste management, setting procedures for exemptions in accordance with Annex V, point 2, and Article 25(4) of Regulation (EU) 2025/40 on packaging and packaging waste, and introducing administrative penalties for non-compliance, with the stated objective of environmental protection and enabling such packaging to be produced as an exception to the recyclability requirements under Regulation (EU) 2025/40, while the proposal remains open for comments until 31 May 2026 and the dates of adoption and entry into force are yet to be determined.
Vietnam	01/04/2026	On 1 April 2026, Decree No. 110/2026/ND-CP was issued by the Government of Vietnam, establishing a framework for extended producer responsibility (EPR) requiring manufacturers and importers to meet mandatory recycling targets or make financial contributions in relation to specified products and packaging, with the decree setting out obligations for compliance with recycling requirements and financial mechanisms under the national EPR regime, and entering into force on 25 May 2026.
EU Commission	13/04/2026	The European Commission has launched a public consultation on the Waste Early Warning Report 2027, seeking feedback on the assessment of Member States’ progress towards EU waste targets, including recycling and preparation for reuse objectives, as part of its monitoring and evaluation framework under EU waste legislation, with stakeholders invited to submit comments through the “Have Your Say” portal in advance of the preparation and publication of the report.
USA- Minnesota Pollution Control Agency	15/04/2026	On 15 April 2026, the Minnesota Pollution Control Agency announced an extension of the initial reporting deadline under Minnesota’s PFAS in products law (“Amara’s Law”), postponing the obligation for manufacturers to report intentionally added per- and polyfluoroalkyl substances (PFAS) in products sold, offered for sale or distributed in the state from 1 July 2026 to 15 September 2026, with reports required to include information on product description, PFAS substances, concentrations, functional use and manufacturer details, and with the possibility for manufacturers to request a 90-day extension until 14 December 2026, as part of the implementation of statutory reporting requirements aimed at collecting data on PFAS use in products and supporting broader restrictions on PFAS under Minnesota law.
CEN	15/04/2026	The European Committee for Standardization has published EN 18120, a European standard establishing requirements and criteria for the design of packaging to improve recyclability, setting out specifications relating to material selection, packaging structure and compatibility with sorting and recycling processes, with the standard defining design considerations intended to facilitate the effective recycling of packaging within existing waste management systems, as set out in the official standard documentation.
China	17/04/2026	Guidelines for the Green Design of Industrial Products (2026 Edition) was jointly issued by five departments, this guidelines aims to reduce or control resource consumption and environmental impacts throughout the entire life cycle, starting from the design phase, setting out requirements and considerations related to environmentally sustainable product design and lifecycle impacts, as described in the article, with the measure forming part of China’s broader policy framework on green manufacturing and industrial sustainability.
Sweden	17/04/2026	In April 2026, the Government of Sweden announced that it will develop a national action plan to address per- and polyfluoroalkyl substances (PFAS), with the initiative aimed at strengthening measures to reduce emissions, limit exposure and improve the management of PFAS in Sweden, including the intention to coordinate actions across relevant authorities and policy areas, assess existing regulatory and policy frameworks, and identify further measures to address PFAS-related risks, as set out in the government communication, with the work forming part of Sweden’s broader efforts to address environmental and health impacts associated with PFAS.

Thank you for reading the latest sustainability regulatory updates!

 

Have a question for our sustainability experts?