Sustainability regulatory updates, the circular economy and the environment
The table below summarises the most recent publications regarding sustainability regulatory updates, the circular economy, and the environment (non-exhaustive).
| Entity | Date | Publication |
| European Commission SCHEER (Scientific Committee on Health, Environmental and Emerging Risks) | 07/04/2025 | Scientific Opinion on “Draft Environmental Quality Standards for PFAS total under the Water Framework Directive” |
| Republic of France | 20/05/2025 | Resisting deregulation at the expense of human rights and environmental protection – Opinion on the European Commission’s “Omnibus I Directive proposal” (A-2025-5) The Commission nationale consultative des droits de l’homme (CNCDH) T strongly criticises the EU’s proposed “Omnibus I” directive, warning that it threatens recent progress on corporate sustainability. While the directive is presented as reducing red tape, the CNCDH argues it would undermine human rights and environmental protections by delaying key obligations, weakening due diligence in supply chains, and reducing legal accountability. The opinion also criticises France’s support for the proposal and warns against limiting civil society input and weakening climate and enforcement measures. |
| European Commission | 23/05/2025 | The European Commission has introduced new measures to accelerate the EU’s shift toward a low-carbon economy. Four pieces of secondary legislation, along with a communication on the Net-Zero Industry Act (NZIA), aim to strengthen the resilience and competitiveness of European industry while lowering its carbon emissions. These rules define which manufacturing projects qualify for key benefits under the Act—such as streamlined permitting, strategic project designation, and evaluation based on non-price criteria. The goal is to boost the production of net-zero technologies, cut greenhouse gas emissions, and harness the EU’s clean tech potential.
The Commission has adopted the following acts: |
| European Commission | 24/05/2025 | Public Consultation for Roadmap towards Nature Credits: Nature boosts human well-being and economic resilience by providing vital ecosystem services and supporting climate action. To protect and restore nature, the EU aims to develop high-integrity nature credits and certifications that attract private investment, complement public funding, and reward land and resource stewards like farmers and fishers. These tools are intended to turn nature protection into a sustainable source of income and value creation.
Feedback period: 7 July 2025 – 30 September 2025 |
| European Commission | 06/06/2025 | Initiative on Rules for the calculation and verification of average loss rates for sorted waste:
The Commission aims to establish uniform, simple and proportionate rules for the calculation, verification and reporting of the weight of materials or substances lost after a waste sorting operation, and which are not subsequently recycled, based on average loss rates for sorted waste. The uniform rules will ensure that data supporting the calculation of recycling rates are comparable and reliable. Currently under preparation. |
| European Commission | 06/06/2025 | Public Consultation for Initiative on Green-listing certain waste for the purposes of shipments to recovery between Member States. This initiative implements the new Waste Shipments Regulation and complements the objectives of the future Circular Economy Act.
It will consider certain waste as green-listed and may also introduce contamination thresholds so that other types of waste can be green-listed. The initiative will be preceded by a consultation process to gather input from a wide range of stakeholders on waste streams to be addressed. Consultation period: 2 July 2025 – 31 October 2025 |
| European Council | 10/06/2025 | The Council and Parliament reach an agreement to make detergents safer for both people and the environment. The agreement, among other things, allows the European Commission to impose stricter biodegradability standards for water-soluble detergent capsules and assess whether similar criteria should apply to other major organic ingredients in detergents. It also includes a revision clause enabling future tightening of these targets. |
| European Commission | 16/06/2025 | The 2025 “Digital Decade” Staff Working Document emphasises the critical interplay between digital transformation and the energy transition, noting that surging energy needs—particularly from data centers and AI technologies—are challenging the EU’s clean energy capacity and grid infrastructure. The document calls for a stronger alignment of the green and digital transitions—advocating investment in clean and reliable energy sources, smarter grid systems, and integrated policy efforts—to ensure digital infrastructure can grow sustainably and support Europe’s competitiveness, technological sovereignty, and climate goals. |
| European Commission | 16/06/2025 | The Commission Staff Working Document on the Monitoring of the European Declaration on Digital Rights and Principles, evaluates how the EU and its Member States are implementing the Declaration’s commitments. Chapter VI specifically addresses the digital transition’s environmental dimension, noting only moderate progress. Though EU action—such as data Centre reporting requirements, the Digital Product Passport under ESPR Regulation, and Directive on Common Rules Promoting the Repair of Goods —has laid important groundwork, many Member States show uneven engagement. The report highlights promising practices and tools but underscores persistent gaps in communication, coordination, and consistency in embedding sustainability and digital rights across the EU. |
| European Commission | 19/06/2025 | Public consultation for Nature Restoration Regulation – science-based method for monitoring pollinator diversity and pollinator populations. Under the Nature Restoration Regulation, EU countries are required to:
To get appropriate data to assess these targets, EU countries must monitor the abundance and diversity of pollinator species. The Commission is proposing a science-based methodology for this data collection. Feedback period: 19 June 2025 – 17 July 2025 |
| European Commission JRC (Joint Research Centre) | 20/06/2025 | New EU labels to help consumers choose more repairable electronics: The Commission has introduced a new repairability score system, which will be displayed on the new Energy Label that accompanies these electronic products. This way, consumers will be able to make more sustainable choices when purchasing these products. |
Sustainability regulatory updates from July 2025
European sustainability regulatory updates
Omnibus
CBAM – Carbon Border Adjustment Mechanism
The Council of the European Union has adopted its negotiating stance on simplifying the Carbon Border Adjustment Mechanism (CBAM) as part of the Sustainability Omnibus Package. It supports the Commission’s February 2025 proposal to replace the current limited exemption with a new mass-based exemption for importers of less than 50 tons of goods. The Council also suggests further streamlining of authorisation processes, data collection, and emissions reporting requirements. Negotiations with the European Parliament will begin soon.
Council of the European Union releases third Presidency compromise on Omnibus Directive proposal
The Council of the European Union’s third Presidency compromise proposal on the Omnibus Directive, prepared for the 4 June 2025 Antici Group meeting, outlines significant changes to the Commission’s original draft. Key amendments include raising the reporting threshold under the Taxonomy Regulation to companies with over 1,000 employees and €450 million in turnover, and easing disclosure obligations for smaller companies and suppliers. It also introduces protections for sensitive commercial data and trade secrets. The proposal calls for revising the ESRS (European Sustainability Reporting Standards) to streamline data points, prioritise quantitative over narrative reporting, and clarify what is mandatory. Additionally, it allows Member States more flexibility on penalties and proposes two due diligence approaches: a full risk-based model or a limited Tier 1 approach, moving away from entity-based obligations. The official proposal was released on 21 June.
European Parliament committees propose changes to Omnibus Directive
The European Parliament has released proposed amendments to the Omnibus Directive from the Committees on International Trade (INTA), and Environment Climate and Food Safety (ENVI). The amendments reflect differing political positions among MEPs. Some call for rejecting the Commission’s proposal entirely, arguing it undermines key corporate sustainability rules. Others suggest significantly raising the thresholds for company obligations—proposing thresholds of 5,000 or even 10,000 employees, alongside financial criteria such as €1.5 billion in net turnover or €2 billion in balance sheet total.
Batteries
After publishing the fourth Simplification Omnibus package on 21 May 2025, the European Commission launched a public consultation on its proposal to postpone the due diligence obligations under the Batteries Regulation (Regulation (EU) 2023/1542) by two years. The consultation is open until 31 July 2025.
EFRAG publishes draft comments on ISSB Climate Disclosure Amendment
EFRAG has released its Draft Comment Letter (DCL) in response to the ISSB’s Exposure Draft on proposed amendments to IFRS S2 regarding greenhouse gas emissions disclosures. Stakeholders are invited to submit their comments on EFRAG’s draft by 20 June 2025. This DCL forms part of the ISSB’s due process and considers how IFRS S2 applies to entities reporting under the European Sustainability Reporting Standards (ESRS), particularly as a source of industry-specific guidance. In its preliminary view, EFRAG supports the temporary omission of disclosures related to emissions from derivatives, financed activities, and insured emissions, suggesting these exclusions be revisited as reporting practices and methodologies develop.
European Climate Advisory Board recommends 90–95% emissions cut by 2040
The European Scientific Advisory Board on Climate Change (ESABCC) has recommended, among other things, that the EU set a 2040 target of reducing net domestic greenhouse gas emissions by 90–95% compared to 1990 levels. In its latest report, the Board highlights solid progress—particularly in wind and solar energy—but notes disparities across sectors and countries. The ESABCC stresses that a clear 2040 goal would enhance long-term policy certainty, accelerate clean technology deployment, and reduce reliance on fossil fuel imports. It also urges alignment with global climate goals ahead of COP30 and advises against using international carbon credits.
Ecodesign and energy labelling working plan for 2025-2030
Starting June 2025, new EU Ecodesign and energy labelling regulations apply to smartphones, tablets, and cordless phones, aiming to boost durability, energy efficiency, and repairability. Devices must now meet standards like resistance to drops and water, batteries lasting 800+ charge cycles, software updates for 5+ years, and access to spare parts for at least 7 years. A new energy label includes energy use, durability, and a repairability score (A to E) to help consumers make informed choices. These rules are expected to cut energy use by 2.2 TWh and save EU consumers up to €20 billion by 2030, while promoting circular economy goals. Developed under the 2020 Circular Economy Action Plan, the regulations support the EU’s broader green and digital transitions. More information here.
New Environmental Footprint Rules for apparel and footwear
On the 25th of June 2025, the European Commission approved the new Product Environmental Footprint Category Rules (PEFCR) for apparel and footwear.
The PEFCR are detailed guidelines which provide a standardised, science-based method to assess environmental impacts across the entire product lifecycle, from raw material extraction, production, and logistics to use and end-of-life. This enables companies to measure their environmental footprint and identify where improvements can be made through sustainable design and production practices.
The apparel and footwear PEFCR cover all categories of garments and footwear with 13 product sub-categories.
Apparel & footwear PEFCR: 13 product sub-categories
| T-shirts | Underwear | Footwear – Boots |
| Dresses | Socks | Footwear – Shoes |
| Sweaters | Swimwear | Footwear – Sandals |
| Trousers | Shirts | |
| Jackets | Skirts |
These categories were selected based on their market relevance and representativeness, and each comes with predefined assumptions (e.g., number of wears, washing frequency, material composition) to streamline the footprint calculation.
The essential factors which are considered in the PEFCR to improve the environmental footprint of apparel and footwear are:
- Circularity (use of recycled materials, recycling of the product)
- Durability (extending the life of apparel and footwear)
- Repairability
- Fibre fragments (microplastics, small pieces of fibre)
- Life cycle focus of the product.
For more information, consult the European Product Environmental Footprint website here.
Standard updates
The table below summarises the most recent standard updates and upcoming dates of withdrawal (non-exhaustive):
(*) Date of withdrawal: Latest date by which national standards conflicting with a European Norm (EN) (and Harmonisation Document (HD) for the European Committee for Electrotechnical Standardisation (CENELEC)) must be withdrawn.
(**) Date of availability: Date when the definitive text in the official language versions of an approved CEN/CENELEC publication is distributed by the Central Secretariat.
The European Committee for Standardisation (CEN)/CENELEC
| Reference | Title | Date of available (**) | Supersedes |
| CWA 18186:2025 | Guidelines to create a Digital Product Passport – the EU project CircThread experience | 2025-05-21 | |
| Reference | Title | Date of withdrawal (*) | Supersedes |
| EN 15347-2:2025 | Plastics – Sorted plastics wastes – Part 2: Quality grades of sorted polyethylene (PE) wastes and specific test methods | 2025-11-30 | |
| EN 15347-3:2025 | Plastics – Sorted plastics wastes – Part 3: Quality grades of sorted polypropylene (PP) wastes and specific test methods | 2025-11-30 | |
| EN 15347-4:2025 | Plastics – Sorted plastics wastes – Part 4: Quality grades of sorted poly(ethylene terephtalate) (PET) wastes and specific test methods | 2025-11-30 | |
| EN 15347-5:2025 | Plastics – Sorted plastics wastes – Part 5: Quality grades of sorted poly(vinyl chloride) (PVC) wastes and specific test methods | 2025-11-30 | |
| EN 15347-6:2025 | Plastics – Sorted plastics wastes – Part 6: Quality grades of sorted polystyrene (PS) wastes and specific test methods | 2025-11-30 |
Publications on European Commission initiatives
The table below summarises recent publications on European Commission initiatives:
| Date | Title |
| 27/05/2025 | Obligation to repair – inclusion of local space heaters in Annex II of Directive promoting the repair of goods
The purpose of this initiative is to add ‘local space heaters’ to Annex II on the repair of goods. The repairability requirements for local space heaters have been established under Commission Regulation (EU) 2024/1103. The European Commission is preparing the draft act. |
| 12/06/2025 | Sustainable products – disclosure of information on unsold consumer products
This initiative will specify:
The feedback period closed on the 10 July 2025. |
| 19/05/2025 | Consumer Agenda 2025-2030 and action plan on consumers in the Single Market
The new consumer policy strategy is intended to:
The strategy contains a list of measures to be taken in 2025-2030, including:
The public consultation period is open until 31 of August 2025. |
Denmark sustainability regulatory updates
New requirements concerning packaging and other waste
On the 4th of June 2025, the Danish Ministry of the Environment and Gender Equality submitted to the European Commission a text related to amending an order on certain requirements concerning packaging, extended producer responsibility for packaging, and other waste collected with packaging waste (2025/0279/DK).
The main points of this order are:
- Beverage containers and cups for beverages are not exempt from rules
- The obligation for producers to pay towards the collection of waste from municipalities applies to both collection and transport
- Historical deadlines are deleted, and references updated, in certain provisions and annexes
- Added requirements for packaging, extended producer responsibility for packaging and other waste collected with packaging waste
- A few minor clarifications and consequential corrections
US sustainability regulatory updates
Vermont amends PFAS law
In May 2024, the State of Vermont signed S.25 into law, launching its first comprehensive PFAS ban in a wide range of consumer products, including aftermarket stain and water-resistant treatments, artificial turfs, class B firefighting foams, cookware, cosmetics and menstrual products, food packaging, incontinency protection products, juvenile products, residential rugs and carpets, ski waxes, and textiles.
On 11 June 2025, Vermont approved H.238 to amend its PFAS law by broadening the scope, clarifying definitions and refining timelines.
Summary of the amendments:
New product categories
- Cleaning products (general cleaners, hand soaps) – intentionally added PFAS prohibited starting 1 July 2027
- Dental floss – intentionally added PFAS prohibited starting 1 July 2027
- Fluorine-treated containers – intentionally added PFAS prohibited for sale or distribution starting 1 July 2027; intentionally added PFAS prohibited for manufacture starting 1 July 2032
- Personal protective equipment (PPE) – intentionally added PFAS requires written notice from 1 July 2025; intentionally added PFAS prohibited starting 1 July 2029
Revised timelines
- Cookware ban delayed by 2.5 years; originally set for 1 January 2026, now 1 July 2028
Canada sustainability regulatory updates
The Competition Bureau of Canada issues final guidelines on environmental claims
The Competition Bureau of Canada has published its final environmental claims guidelines, following two rounds of public consultation. These guidelines are intended to help businesses comply with the Competition Act, particularly considering new anti-greenwashing provisions that came into effect on 20 June 2024.
This bulletin provides an overview of key updates and their implications for businesses making environmental claims in Canada.
What is considered an environmental claim?
The Bureau defines “environmental claims” as any representation related to the environment made to promote a product, service, or business.
“Greenwashing” refers to claims that mislead consumers by exaggerating, fabricating, or failing to properly support environmental benefits. These practices are now directly addressed under the revised Competition Act.
New provisions in the Competition Act
Two new provisions were introduced to directly address greenwashing:
- Product environmental claims: Claims about a product’s benefits to the environment, such as protecting ecosystems, restoring resources, or mitigating climate impact, must be backed by adequate and proper testing conducted before the claim is made
- Business or operational environmental claims: Claims about a business’s operations or goals (e.g., “carbon neutral supply chain”) must be substantiated using reliable evidence grounded in an internationally recognised method
These new provisions build upon existing deceptive marketing provisions under the Competition Act, which prohibit false or misleading representations and require product performance claims to be based on adequate and proper testing.
Key principles for making environmental claims
To ensure compliance with the Competition Act and reduce the risk of greenwashing, the Competition Bureau of Canada recommends that businesses consider the following principles when making environmental claims:
- Be truthful and not misleading: Ensure that environmental claims are accurate and not misleading in their overall impression. According to the Bureau’s guidance, even a technically correct statement may still mislead consumers if it implies a broader or more significant benefit than what is substantiated. Disclaimers or fine print should not be used to correct an otherwise misleading message.
- Back claims with proper testing or evidence: Product-related claims should be supported by adequate and proper testing conducted in advance. For claims related to business operations or goals, the Bureau recommends using internationally recognised methodologies and sufficiently rigorous evidence to support the claim.
- Use clear and specific language: Avoid vague or general terms such as “green” or “eco-friendly” unless clearly defined. The Bureau recommends that claims should identify what specifically is being referred to, whether a component, product, service, or the entire business activity.
- Avoid overstating or exaggeration: The Bureau’s guidance discourages overstating minor environmental benefits or implying impacts that cannot be adequately supported. Claims should remain proportionate and fact-based.
- Clarify comparative claims: When making comparisons (e.g., to earlier products or competitors), the Bureau recommends that businesses specify what is being compared, the basis for the comparison, and any relevant context or conditions.
- Support future-oriented claims with credible plans: Future claims (such as “net-zero by 2050”) should be substantiated with a credible and verifiable plan, including interim targets and steps already underway. According to the Bureau, such claims should be grounded in an internationally recognised method.
The Competition Bureau of Canada strongly encourages all businesses to review the complete guidelines before making or revising any environmental marketing claims. The final guidelines are available on the Government of Canada’s website here.
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