Sustainability regulatory updates, the circular economy and the environment

 

Europe

JRC publishes methodology for defining Digital Product Passport data requirements under ESPR

On March 2026, the European Commission Joint Research Centre published the report “Methodology for defining data requirements for the Digital Product Passport under the ESPR framework”; the report sets out a step-by-step methodology to define which data should be included in Digital Product Passports (DPPs) under the Ecodesign for Sustainable Products Regulation (ESPR) and the justification for their inclusion, focusing on the semantic definition and prioritisation of information requirements within the DPP context, while analysing existing industry data collection and data-sharing practices across product value chains; it translates policy objectives and use cases into structured data needs and classifies them as essential, strongly recommended or voluntary based on value–effort and feasibility assessments, and addresses certain technical aspects such as data access rights, data governance and data granularity where necessary, while leaving system architecture and implementation outside its scope, with the methodology intended to support ESPR delegated acts and impact assessments and designed to be modular and applicable beyond the ESPR framework where relevant analyses are conducted.

 

EU Omnibus I Directive Formally approved: major changes to CS3D and CSRD

On 26 February 2026, the European Council published the Directive 2026/470 amending Directive (EU) 2022/2464 and Directive (EU) 2024/1760, together with related provisions in Directives 2006/43/EC and 2013/34/EU, as part of measures to simplify sustainability reporting and due diligence requirements.

Key changes to CSRD:

• Scope: Applies to undertakings, groups and issuers with more than 1,000 employees and net turnover exceeding €450 million.
• Third-country companies: Threshold set at €450 million EU turnover, with a €200 million threshold for the relevant subsidiary or branch.
• Value-chain cap: Undertakings with fewer than 1,000 employees may decline to provide information exceeding the voluntary reporting standard.
• Sector-specific standards: The mandate for the Commission to adopt sector-specific reporting standards is removed, with the possibility to provide sector-specific guidance instead.
• Temporary relief: Member States may exempt certain undertakings from reporting requirements for financial years beginning between 1 January 2025 and 31 December 2026.

Key changes to CS3D

• Scope: Applies to companies with more than 5,000 employees and net worldwide turnover above €1.5 billion.
• Due diligence: Companies must base their due diligence on reasonably available information.
• Climate transition plans: The provisions concerning the transition plan for climate change are repealed.
• Liability and penalties: The EU-wide harmonised liability regime is removed, and Member States must set a maximum limit for pecuniary penalties of 3% of net worldwide turnover.

Timeline

Member States must adopt and publish national measures by 26 July 2028 and apply them from 26 July 2029, with one provision applying for financial years starting on or after 1 January 2030. The decision is grounded in Regulation (EC) No 66/2010, the legal framework governing the EU Ecolabel program. Under Article 8(2), the Commission has the power to set, update, or extend the validity of ecolabel criteria for specific product groups. The act was adopted on 23 December 2025 and published in the Official Journal of the European Union on 6 January 2026. It is now in force.

 

Safe and Sustainable by Design and ESPR

The European Commission has published Recommendation revising the framework for Safe and Sustainable by Design (SSbD) chemicals and materials.

It establishes a European reference framework for research, innovation, and industrial development. The objective is to ensure that chemicals and materials are safer for human health and more environmentally sustainable across their lifecycle.

The framework promotes the integration of safety and sustainability considerations at the early stages of innovation and covers the full lifecycle: design, production, use, and end-of-life.

It encourages uptake by industry, Member States, research organisations, and higher-education institutions. It also supports the substitution of substances of concern with safer alternatives.

The Safe and Sustainable by Design framework is linked to ESPR implementation. The ESPR requires that, when setting product performance requirements, the Commission takes into account existing chemical safety assessments and SSbD criteria.

This leads to several consequences:

First, for product design requirements, ecodesign rules may increasingly integrate SSbD criteria, with a focus on safer substances and more sustainable materials.

Second, for delegated acts, future ESPR measures may include requirements based on SSbD, particularly in relation to substances of concern and material selection.

Third, the SSbD framework promotes a lifecycle approach. This aligns with ESPR objectives on environmental performance, circularity, and resource efficiency.

 

Commission Implementing Decision on Calculation on recycled plastic content in single-use plastic beverage bottles

On 9 March 2026, the European Union notified to the World Trade Organization of a draft Commission Implementing Decision laying down rules for the calculation, verification and reporting of recycled plastic content in single-use plastic beverage bottles made of polyethylene terephthalate (PET) of up to 3 litres; the draft establishes how EU Member States must demonstrate compliance with recycled content targets under Directive (EU) 2019/904, including rules based on existing EU food contact legislation for mechanical recycling and mass balance accounting with third-party certification for chemical recycling, and defines conditions under which recycled plastic may be counted, with the objective of ensuring environmentally sound recycling practices; the final date for comments is 23 April 2026, with adoption planned for Q2 2026 and entry into force 20 days after publication.

 

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

 

Entity	Date	Publication
EU Commission	05/03/2025	The European Commission has proposed a Regulation establishing a framework of measures to accelerate industrial capacity and decarbonisation in strategic sectors, targeting energy-intensive industries, net-zero technologies and the automotive value chain, with measures to streamline permitting, support the deployment of low-carbon technologies and strengthen industrial resilience and supply chains, as part of efforts to enhance EU competitiveness and support the transition to climate neutrality
European Parliament	06/03/2025	The European Parliament Research Service briefing reports that, on 8 December 2025, the European Parliament and the Council reached a provisional agreement on the proposed Regulation on forest reproductive material (FRM), which would replace the existing directive and extend its scope to include both material for forestry purposes and for the conservation of forest genetic resources, introduce requirements for assessing the sustainability and climate suitability of basic material used for FRM production, and allow Member States to establish contingency plans to ensure supply in the event of extreme weather, wildfires, pests or other disruptions, while providing more flexible rules for material used for conservation purposes.
Denmark	01/02/2026	Denmark has adopted a new Executive Order on food contact materials, establishing national measures under Regulation (EC) No 1935/2004 and setting specific requirements for materials such as ceramics, enamelled articles, glass, paper and board, including rules on composition, migration limits (e.g. for lead and cadmium), permitted substances, and mandatory declarations of compliance and documentation obligations for operators, as well as provisions on traceability, withdrawal of non-compliant products and penalties for infringements; the Order also incorporates and enforces several EU acts on food contact materials and introduces transitional provisions, entering into force on 1 January 2026, with certain requirements applying from 1 July 2026.
Taiwan	12/02/2026	On 12 February 2026, Taiwan’s Ministry of Environment published a draft amendment to the Regulations for Restricting the Import of Mercury-Containing Products in the Executive Yuan Gazette, proposing additional import prohibitions on specified mercury-containing products and revised conditions for permitted imports, with a public consultation period open until 14 April 2026.
TRIS/Denmark	23/02/2026	The XD Textile Responsable is a programme supported by France’s ADEME aimed at accelerating innovation toward a more responsible textile sector by addressing key systemic issues in production, consumption and circularity. It seeks to reduce textile volumes while strengthening local economies and employment through solutions that shorten value chains, promote ecological design, and connect actors across the textile lifecycle — from producers and distributors to repairers and consumers — with the goal of increasing durability, reducing unused garments, supporting repair services and making responsible clothing more accessible. The initiative is structured into phases starting with an appel à manifestation d’intérêt open from 18 December 2025 to 27 February 2026 to identify actors and challenges, followed by an ideation stage from March 2026 and eventual prototype financing in 2027, with thematic workgroups on topics such as taxation, consumer behaviour and quality standards to foster collective action across the sectors.
Gov.UK	24/02/2026	The UK government has published its approach to the UK REACH Candidate List of Substances of Very High Concern (SVHCs), setting out how substances will be identified and added to the list under the UK REACH regime, with the Health and Safety Executive (HSE) prioritising substances based on hazard properties and potential exposure, and following a process that includes public consultation before decisions are finalised; the document clarifies that inclusion on the Candidate List signals that a substance may be subject to future authorisation requirements and imposes immediate information duties in supply chains, while also outlining how the UK system will operate independently from the EU REACH framework.
UK.GOV	25/02/2026	The UK government has made the UK Sustainability Reporting Standards (UK SRS) S1 and S2, based on the ISSB framework, available for voluntary use, marking a step towards a future UK regime for sustainability and climate-related disclosures, while it continues to assess which companies will be required to report under these standards and how they will be formally integrated into the regulatory framework
EU Commission	25/02/2026	The European Commission initiative on a delegated act under the Packaging and Packaging Waste framework sets out proposed exemptions from reuse obligations for plastic wrappings and straps, defining cases where reuse may not be required due to technical or environmental considerations, and was subject to a feedback period that closed on 9 January 2026, marking the end of stakeholder input ahead of further development of the measure within the EU legislative process.
EU Commission	25/02/2026	The European Commission has approved a draft Implementing Decision establishing a harmonised EU methodology for calculating, verifying and reporting recycled plastic content in single-use plastic beverage bottles under Directive (EU) 2019/904, setting out how Member States must calculate recycled content based on the proportion of recycled plastic in PET bottles placed on the market, defining the scope to include bottles up to 3 litres with their components, introducing mass-balance accounting rules for processes where recycled content cannot be physically traced, and requiring batch-level declarations, third-party verification in certain cases, and annual reporting by Member States, with the measure set to enter into force 20 days after its publication in the Official Journal once formally adopted.
EU Council	26/02/2026	The Council of the European Union has adopted conclusions emphasising the need to strengthen consumer protection in support of sustainable consumption, calling for more effective enforcement of existing rules and a simplified regulatory framework, while highlighting the importance of enabling consumers to make informed and environmentally responsible choices and addressing challenges linked to the green and digital transitions.
TRIS/ LUXEMBURG	02/03/2026	Luxembourg has submitted a draft technical regulation to the EU Technical Regulation Information System (TRIS) concerning amendments to draft law No 8482 on waste, packaging and the impact of certain plastic products on the environment, aiming to align national legislation with EU law, including Directive 94/62/EC on packaging and packaging waste, by introducing technical and editorial adjustments, removing provisions that could conflict with EU law—such as the early implementation of packaging bans foreseen under Regulation (EU) 2025/40—and simplifying the legal framework to ensure legal certainty and compliance with EU principles.
The European Chemicals Agency (ECHA)	03/03/2026	The European Chemicals Agency (ECHA) Risk Assessment Committee (RAC) has adopted its opinion on the proposed restriction of per- and polyfluoroalkyl substances (PFAS) under the REACH Regulation, concluding its scientific evaluation of the risks posed by PFAS and contributing to the ongoing restriction process, which will inform the European Commission’s decision-making on potential EU-wide measures to limit the manufacture, use and placing on the market of these substances.
TRIS- Finland	04/03/2026	Finland has submitted a draft Government Decree to the TRIS system under Directive (EU) 2015/1535, establishing rules on compensation to be paid by producers of certain plastic products to municipalities for the period 2026–2028, together with amendments to Section 1 and Annexes 1 and 3 of the existing decree on certain plastic products. The measure operationalises extended producer responsibility (EPR) by requiring producers to cover costs related to waste management, clean-up and awareness-raising measures associated with plastic products, in line with the framework of Directive (EU) 2019/904 on single-use plastics. The notification reflects a draft technical regulation at pre-adoption stage, subject to the TRIS standstill procedure.
EU Commission	04/03/2026	The Council of the European Union has published a proposal for a Regulation establishing a framework of measures for the acceleration of industrial capacity and decarbonisation in strategic sectors, setting out the Council’s examination of the proposal, which aims to strengthen EU industrial resilience and competitiveness by accelerating permitting procedures, supporting the deployment of low-carbon technologies and reducing strategic dependencies in sectors such as energy-intensive industries, net-zero technologies and the automotive value chain, while also amending Regulations (EU) 2018/1724, (EU) 2024/1735 and (EU) 2024/3110 as part of the legislative process.
EU Council	05/03/2026	The Council of the European Union has given its final approval to the EU’s 2040 climate target, endorsing a binding objective to reduce net greenhouse gas emissions by 90% by 2040 compared to 1990 levels, as part of the EU Climate Law framework, thereby strengthening the EU’s trajectory towards climate neutrality by 2050 and providing a reference point for future legislative measures, investment planning and sectoral policies, while also reinforcing the EU’s commitments under the Paris Agreement and guiding the next phase of climate policy development.
EU Textile Ecosystem Platform	06/03/2026	The European Commission’s Transition Pathway for Textiles highlights due diligence in textile recycling, drawing on an OECD report addressing risks in garment and textile supply chains, and identifies key environmental and social challenges linked to textile waste streams, including traceability, material composition and waste handling, while outlining approaches for stakeholders to mitigate these risks through improved supply chain transparency, responsible sourcing practices and better data on recycling processes, supporting the transition towards a more circular and sustainable textiles sector in the EU.
EU Commission	09/03/2026	The European Commission has launched a feedback initiative on updated reporting requirements for pollutants from industrial activities under Regulation (EU) 2024/1244, proposing changes to improve the quality, consistency and scope of environmental data reported by operators, with the aim of enhancing transparency and supporting monitoring of industrial emissions and their environmental impacts, with the initiative planned for adoption in the first quarter of 2026.
CEN	09/03/2026	On 11 March 2026, CEN published the European standard EN ISO 1158:2026, “Plastics – Vinyl chloride homopolymers and copolymers – Determination of chlorine content (ISO 1158:2026)”; the standard specifies two methods for determining the chlorine content of vinyl chloride homopolymers and copolymers free from plasticizers or additives, namely method A based on combustion in a bomb and method B based on combustion in a flask, and is identical to ISO 1158:2026 (EQV), within the scope of thermoplastic materials (ICS 83.080.20).
EU Commission	17/03/2026	The European Commission published an initiative for an implementing regulation establishing new functions in the Information System pursuant to Article 33 and Annex III of Regulation (EU) 2023/1115 (EU Deforestation Regulation); the initiative provides for functionalities including the submission of simplified declarations by micro and small primary operators and the assignment of a declaration identifier, access to the system for downstream operators and traders, particularly non-SMEs, and contingency arrangements in case of unavailability of the system, within the environmental policy framework. The adoption is expected for the second quarter of 2026.
EU Commission	19/03/2026	The European Commission published Communication 2026/C 169/05 in the Official Journal of the European Union establishing the 2026 annual Union work programme for European standardisation under Article 8 of Regulation (EU) No 1025/2012; the programme sets out the strategic priorities for European standardisation and identifies the standards and standardisation deliverables the Commission intends to request from European standardisation organisations, with the objective of supporting EU policies and legislation and contributing to priorities such as closing the innovation gap, decarbonising the economy, reducing strategic dependencies and strengthening the Single Market, and highlights priority actions including standards for artificial intelligence and data economy, quantum technologies, construction, cybersecurity and public security, and the green transition, including ecodesign, microplastics and sustainable products; the programme is based on consultations with stakeholders and the High-Level Forum on European Standardisation and includes, in its annex, a detailed list of actions grouped under four main priorities: innovation, decarbonisation and competitiveness, security and reduced dependencies, and the functioning of the Single Market, covering areas such as AI, hydrogen, compostable packaging, critical raw materials, construction products and consumer product safety.

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