Sustainability regulatory updates, the circular economy and the environment

 

Europe

Omnibus Package (CSRD, CSDDD)

On 13 October 2025, the European Parliament has endorsed proposals to simplify EU sustainability reporting and due diligence rules, aiming to reduce administrative burdens on smaller companies while maintaining core transparency standards. The initiative seeks to narrow the scope of the Corporate Sustainability Reporting Directive (CSRD) and adjust the Corporate Sustainability Due Diligence Directive (CSDDD), limiting obligations to larger firms and easing reporting requirements for subsidiaries and SMEs. Parliament emphasizes that the changes should preserve the EU’s sustainability objectives while improving proportionality and regulatory clarity for businesses. These are the key points of the draft:

Sustainability Reporting: Applies only to companies with more than 1,000 employees and a net annual turnover above €450 million.

Due Diligence Obligations: Limited to companies, including non-EU firms with EU turnover, with more than 5,000 employees and turnover above €1.5 billion.

Smaller Companies: Those below the thresholds are excluded from mandatory reporting and due diligence rules but may opt to report voluntarily.

Supply Chain: Large companies cannot compel smaller suppliers to provide information beyond voluntary standards.

Procedure: The Legal Affairs Committee (JURI) adopted the draft by 17 votes to 6, with 2 abstentions. The next step is a full Parliament vote before negotiations with the Council and the Commission.

 

 

CBAM – Carbon Border Adjustment Mechanism

On 29 September 2025, the Council adopted a regulation simplifying and strengthening the EU’s carbon border adjustment mechanism (CBAM), aiming to reduce regulatory burden and compliance costs while maintaining climate ambition. Key changes include a new “de minimis mass” threshold exempting imports up to 50 tonnes per importer per year, temporary allowance of imports in early 2026 pending CBAM registration, and simplifications to authorisation, data collection, emissions calculation, verification, financial liability, as well as adjustments to penalties and rules on indirect customs representatives. The act will be published in the Official Journal and enter into force on the third day following publication.

 

EU Deforestation Regulation:

On 21 October 2025, the European Commission presented a proposal to adjust the EU Deforestation Regulation to ensure smooth and effective implementation. The proposal introduces transitional arrangements, with large and medium-sized companies required to comply from 30 December 2025 and micro and small enterprises from 30 December 2026. It clarifies the scope of due diligence obligations, including traceability and geolocation requirements, and provides for flexibility in information systems during the transition phase. The Commission also proposes clearer definitions for products covered, updated procedures for assessing producer-country risk levels, and strengthened coordination among competent authorities to ensure consistent enforcement and reduce administrative burdens.

Key points:

• The Commission aims to ensure the EUDR’s IT system is fully operational to support traceability of relevant products.
• Micro and small operators from low-risk countries will only need to submit a one-off due diligence statement.
• Downstream operators and traders marketing products already placed on the EU market will not have to file separate statements.
• Application dates:
  Large and medium companies – from 30 December 2025, with a six-month adaptation period.
  Micro and small enterprises – from 30 December 2026.
• These adjustments are designed to simplify compliance and reduce administrative costs while maintaining the EUDR’s environmental objectives.
• The proposal now awaits formal adoption by the European Parliament and the Council.

 

 

Recent publications regarding sustainability regulatory updates, the circular economy, and the environment (non-exhaustive).

Entity	Date	Publication
European Commission	01/08/2025	The European Commission has launched a public consultation on the Circular Economy Act, an initiative designed to establish a comprehensive EU framework promoting resource efficiency, waste reduction, and circular value chains. The proposal aims to integrate circular economy principles into product design, production, consumption, and waste management, ensuring coherence with existing legislation such as the Ecodesign for Sustainable Products Regulation and the Waste Framework Directive. The feedback period runs from 1 August 2025 to 6 November
Japan	09/2025	On September 2025, Japan introduced new certification standards for PET materials used in cosmetic packaging to strengthen product safety and environmental compliance. The updated rules set stricter criteria for recycled PET content, chemical safety, and traceability throughout the supply chain. These standards aim to enhance consumer confidence, promote sustainable packaging practices, and align Japan’s cosmetics packaging regulations with international environmental and quality benchmarks.
Turkey	08/09/2025	Turkish Ministry of Agriculture and Forestry notified the WTO of a draft amendment to the Food Codex Regulation on Food Contact Substances and Materials, officially lifting the ban on recycled plastics in food packaging and introducing rules for reprocessing plastic production scraps. The update also revises departmental references, aligns with environmental and recycling goals, and provides a transition period for businesses to adapt, marking a key step toward circular economy practices in Türkiye’s food packaging sector.
EURATEX	16/09/2025	On 17 September 2025, over 20 European textile and garment organisations signed a declaration at the Première Vision trade fair in Villepinte, France, urging the EU to take immediate regulatory action against ultra-fast fashion. The groups called for a tax on small-parcel deliveries, an end to customs duty exemptions on goods under €150, stricter VAT collection, and stronger enforcement under the Digital Services and Markets Acts. They also urged engagement with Chinese authorities to address online platform practices, citing 4.5 billion ultra-fast fashion parcels entering the EU in 2024 and the resulting rise in textile waste, unfair competition, and harm to SMEs.
EU/WTO	17/09/2025	The European Union also notified the World Trade Organization (WTO) of its intention to revise the requirements for microplastics under the REACH Regulation. The consultation follows recent regulatory developments and aims to refine restrictions to ensure effective implementation and compliance across industries.
EU Council	22/09/2025	On 22 September 2025, the Council of the EU approved a regulation to restrain microplastic pollution by preventing plastic pellet losses throughout the supply chain. Companies must adopt risk management plans, train staff, and ensure clean-up after spills. Large operators require third-party certification, while microenterprises may use simplified declarations. The rules, including measures for maritime transport, will take effect two years after publication in the EU Official Journal following the European Parliament’s final vote in October 2025.
US/ California	22/09/2025	In California, Senate Bill 682 proposes to restrict the use of per- and polyfluoroalkyl substances (PFAS) in many consumer and industrial products. Under the bill: manufacturers of defined ‘covered products’ containing intentionally added PFAS would face prohibitions on sale starting in stages (e.g., as early as January 1 2027 for certain consumer items). The bill includes a ‘currently unavoidable use’ exemption process, whereby manufacturers must demonstrate no safer alternatives exist and that the PFAS use is essential, with renewal reviews. The bill also includes registration and certification requirements, empowers the California Department of Toxic Substances Control to regulate and enforce, and aims to accelerate safer alternative development and phase out non-essential PFAS uses.
ECHA	22/09/2025	European Chemicals Agency is planning a public consultation in spring 2026 on the draft socioeconomic opinion (by its SEAC committee) for the proposed EU-wide restriction of PFAS under REACH. This follows a first consultation in 2023 (March-September) which collected stakeholder input. The 2026 consultation will invite industry, NGOs and other stakeholders to provide feedback on the draft SEAC opinion (not necessarily the hazard/risk opinion from the RAC). The process is part of the broader pathway towards submitting opinions to the Commission and Member States, potentially leading to a final restriction decision
EU Commission	23/09/2025	On 23 September 2025, the European Parliament and the Council adopted Directive (EU) 2025/1892 on environmental liability with regard to the prevention and remedying of environmental damage, repealing Directive 2004/35/EC. The new directive strengthens the “polluter pays” principle by expanding the scope of liable activities, improving enforcement, and enhancing access to justice for affected parties. It also harmonises definitions, reporting obligations, and restoration standards across Member States to ensure more consistent and effective prevention and remediation of environmental harm within the EU.
US/EPA	23/09/2025	Under the Toxic Substances Control Act (TSCA), the U.S. EPA is conducting a risk evaluation of octamethylcyclotetrasiloxane (D4), a cyclic siloxane used in silicones, adhesives, sealants, paints and coatings. In its draft risk evaluation (released September 2025) the Agency preliminarily determined that D4 presents unreasonable risk to workers under 23 conditions of use, to consumers under one condition of use, and to the environment under seven conditions of use. The Agency has not yet finalized the risk evaluation or developed risk-management measures, but such measures may be pursued if a final unreasonable-risk determination is made.
Brazil and California	23/09/2025	California and Brazil have strengthened their collaborative efforts on climate action through a new partnership focused on greenhouse gas reductions, clean energy transitions, sustainable land use, and climate-resilient infrastructure. The initiative involves joint technical exchanges, coordinated policy development, and investment initiatives to support low-carbon pathways. The partnership is designed to leverage California’s regulatory experience and Brazil’s renewable-energy and land-use assets to accelerate global climate mitigation efforts
EU Council	24/09/2025	On 24 September 2025, the Council of the EU approved a “stop-the-clock” mechanism to simplify chemicals legislation and provide greater legal certainty for businesses. The measure allows temporary suspension of regulatory deadlines when updates to EU chemicals law, such as REACH or CLP, are delayed due to pending scientific assessments or procedural steps. This ensures companies are not penalised for delays beyond their control and supports smoother implementation of future chemicals regulations under the EU’s simplification agenda.
EU Parliament	24/09/2025	The European Commission published a delegated act under the Hydrogen and Gas Markets Directive, establishing a methodology for calculating life-cycle greenhouse-gas emissions for a range of low-carbon hydrogen production pathways. The act is designed to bring clarity and regulatory certainty around investments in low-carbon and renewable hydrogen, directly affecting production costs, eligibility, and climate credibility. The act has been submitted to the European Parliament and Council, which have until 10 November 2025 to approve or reject it. It forms a key piece of the EU’s hydrogen policy framework, supporting efforts such as those under REPowerEU to scale up hydrogen deployment in heavy industry, chemicals and transport
Netherlands	24/09/2025	The Netherlands proposed strengthening the EU’s early warning system for harmful chemicals by integrating and analysing existing European data sources. The initiative aims to detect emerging chemical risks faster and coordinate regulatory responses across member states. It would combine data from REACH, CLP, environmental monitoring, and human biomonitoring programmes to identify substances of concern more efficiently. The proposal seeks to enhance public health and environmental protection while supporting the EU’s broader Chemicals Strategy for Sustainability. to specify that this is a Dutch government proposal to the EU, not an EU-adopted measure yet.
ECHA	24/09/2025	The European Chemicals Agency (ECHA) reports that during their September 2025 meetings, the Committee for Risk Assessment (RAC) and the Committee for Socio-Economic Analysis (SEAC) adopted opinions on several key chemicals proposals, including new harmonised classifications, restrictions, and authorisations under the REACH and CLP regulations. The committees also advanced work on substances of very high concern, occupational exposure limits, and PFAS-related proposals. In addition, they announced plans for upcoming discussions on PFAS: for December 2025, the agenda includes electronics and semiconductors (SEAC), PFAS manufacturing (RAC and SEAC), and horizontal issues (RAC and SEAC); for March 2026, it tentatively includes the final discussion and adoption of RAC’s opinion and the discussion and agreement on SEAC’s draft opinion.
EU Commission	25/09/2025	On 25 September 2025, the Council adopted Decision (EU) 2025/1976 on the termination of the Voluntary Partnership Agreement (VPA) between the European Union and the Republic of Cameroon concerning forest law enforcement, governance and trade in timber and derived products (FLEGT). The decision ends the cooperation framework established to ensure that timber exported from Cameroon to the EU complied with national laws, due to limited progress and changing EU timber and deforestation regulations.
EFRAG	25/09/2025	EFRAG released the mappings of digital tools, platforms, and initiatives that support SMEs in sustainability reporting and data management. The publication identifies and categorises available digital resources that can help small and medium-sized enterprises comply with ESRS (European Sustainability Reporting Standards) and broader EU sustainability requirements. This initiative aims to improve accessibility, comparability, and efficiency in SME sustainability reporting by fostering digitalisation and supporting the transition to more transparent and consistent sustainability practices across Europe.
UNECE	26/09/2025	On 26 September 2025, the United Nations published the 11th revision of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS Rev. 11), introducing new provisions to address climate and health risks. The update adds hazard categories for desensitised explosives, new guidance for aerosols, skin corrosion, and eye damage, and clearer rules on environmental persistence and bioaccumulation. It also improves labelling requirements and precautionary statements to enhance worker and consumer safety. Countries adopting GHS Rev. 11 will align their chemical management systems with these updated global standards.
China	27/09/2025	China announced a target to reduce its greenhouse-gas emissions by 7–10 % below peak levels by 2035, marking its first economy-wide absolute reduction target. The move signals a shift away from intensity-based goals, and analysts say it is modest relative to the scale of reduction needed to meet the Paris Agreement’s 1.5 °C trajectory
AAFA	28/09/2025	The American Apparel & Footwear Association (AAFA) sent a letter to New York state authorities urging clarification and alignment of upcoming PFAS restrictions in apparel laws. The association warned that inconsistent definitions and timelines across U.S. states create major compliance challenges for manufacturers and retailers. AAFA called for clear guidance, harmonised standards, and a science-based approach to regulating per- and polyfluoroalkyl substances (PFAS) to ensure feasible implementation while protecting consumers and supporting the apparel industry’s transition toward safer, more sustainable materials.
Mexico	28/09/2025	New Mexico regulators began drafting a rule to require PFAS labelling on consumer products, implementing an optional provision of the state’s PFAS Protection Act (HB 212) signed in April 2025 by Governor Michelle Lujan Grisham. The law gradually phases out PFAS in products sold in the state across multiple sectors, leading to a 2032 ban on most uses of these persistent chemicals, except where classified as currently unavoidable uses (CUUs) or covered by specific exemptions.
EU Council	30/09/2025	The European Commission launched an initiative on public procurement of clean technologies, proposing minimum environmental sustainability requirements for products and services purchased by public authorities. The measure aims to boost demand for clean technologies, reduce greenhouse gas emissions, and support the EU’s Green Deal Industrial Plan. It would establish common criteria for areas such as energy efficiency, resource use, circularity, and lifecycle emissions, ensuring that public spending actively drives the transition toward a climate-neutral and sustainable economy across the European Union.
Spain	10/2025	Spain’s planned extended producer responsibility (EPR) regime for textiles has been delayed following objections from industry stakeholders and regulatory complexity. The draft decree has faced postponements, and key producer and recycling obligations for textiles are now expected to be implemented later than originally foreseen.
OECD	10/2025	The OECD (Organisation for Economic Co-operation and Development) has published a global best-practice guide on chemical data-sharing, designed to support regulators, industry and other stakeholders in improving the safe management of chemicals, facilitating more efficient data exchange, avoiding duplication of testing, and fostering trust between different users of chemical data.
SBTi	10/2025	The Science Based Targets initiative (SBTi) has opened a public consultation on proposed urgent updates to the Forest, Land and Agriculture (FLAG) Guidance and Criteria. The consultation seeks stakeholder feedback on revisions aimed at improving clarity, ensuring consistency with the latest greenhouse gas accounting methodologies, and facilitating the alignment of land-sector targets with the SBTi Corporate Net-Zero Standard. The updates address issues identified during initial implementation and aim to strengthen the credibility and usability of FLAG targets across sectors linked to land use, forestry, and agriculture.
Textile ETP	10/2025	The European Technology Platform for the Future of Textiles and Clothing (Textile ETP) has launched the “Textiles of the Future” initiative to promote innovation and collaboration within the European textile ecosystem. The initiative brings together industry, research, and technology partners to develop a shared vision and roadmap for the future of textiles, focusing on advanced materials, digitalization, sustainability, and new business models. It aims to strengthen Europe’s global leadership in textile innovation and support the transition towards a more resilient, circular, and competitive sector.
ECHA	10/2025	The European Commission has launched a public consultation for a proposal establishing a basic regulation for the European Chemicals Agency (ECHA). The aim is to update and consolidate ECHA’s legal framework to enhance its efficiency, governance, and overall functioning in line with current EU policies. The proposal seeks to clarify ECHA’s role, strengthen its scientific and technical support for chemical risk management, and improve transparency and stakeholder engagement. This initiative is part of the broader effort to ensure that ECHA’s operations remain effective and aligned with the EU’s chemicals strategy for sustainability. Feedback Period open until 02/12/2025
Germany	01/10/2025	Six German fashion and textile trade associations—GermanFashion, BTE, BSI, HDE, bevh, and textil+mode—have issued a joint statement outlining their proposal for the design of a national extended producer responsibility (EPR) system for textiles. The associations call for a uniform national solution to ensure legal clarity, equal treatment, and efficient implementation across the industry. Their concept emphasizes close cooperation between all stakeholders in the textile value chain and highlights the need for a practical and economically viable system that supports circularity and sustainability in the German textile sector.
European Commission	10/2025	The European Commission has launched a Call for Evidence for an evaluation and impact assessment on the revised ecodesign and energy labelling requirements for refrigerating appliances. The initiative aims to update Commission Regulations (EU) 2019/2019 and 2019/2016 to reflect technological progress and strengthen contributions to energy efficiency, circular economy, and sustainability. It will assess the effectiveness, efficiency, and relevance of current rules, identify opportunities to improve material efficiency, labelling information, and product definitions, and explore potential regulatory options including revised requirements and scope extensions. The evaluation will conclude in Q4 2025, with the impact assessment reviewed by the Regulatory Scrutiny Board in Q4 2026, and adoption of new measures expected by the third quarter of 2028.
Republic of France	16/09/2025	On 16 September 2025, Finland notified the European Commission of a draft government bill proposing amendments to the Waste Act and related legislation. The proposed changes aim to implement the EU Batteries Regulation and an amendment to the Waste Electrical and Electronic Equipment Directive into national law. The draft legislation includes supplementary provisions for the Åland Islands, applying Finland’s national regulations through “blanket legislation.” The notification initiates a standstill period until 17 December 2025, during which the draft cannot be adopted unless the Commission or other Member States raise objections.
EU Commission	17/09/2025	The European Commission has published a draft Delegated Regulation proposing amendments to Regulation (EU) 2024/1735, aiming to identify sub-categories within net-zero technologies and specify components primarily used for their production. This initiative seeks to enhance the EU’s net-zero technology manufacturing ecosystem by providing a detailed list of final products and components essential for various technologies, including solar, wind, battery storage, hydrogen, and carbon capture. The regulation is based on a comprehensive assessment considering factors like commercial availability and technological developments, with input from stakeholders and Member States. The draft regulation is open for feedback until 30 November 2025.
JRC	18/09/2025	A new Joint Research Centre (JRC) analysis finds that implementing circular economy measures could reduce CO₂ emissions from heavy industry by up to 231 million tonnes per year in the EU. The report highlights that greater use of recycled materials, product lifetime extension, and industrial symbiosis could significantly cut emissions from sectors such as steel, cement, aluminium, and chemicals. It also notes that circular strategies can lower production costs, strengthen resource security, and support the EU’s transition toward climate neutrality while maintaining industrial competitiveness.

 

 

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