Sustainability regulatory updates, the circular economy and the environment

 

Europe

Omnibus Package (CSRD, CSDDD & CBAM)

On the 20^th of August 2025, the European Economic and Social Committee (EESC) issued an opinion on the Commission’s proposal to amend Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 regarding corporate sustainability reporting and due diligence. The EESC highlights its concern at the short consultation timeframe and limited stakeholder inclusion, and calls for simplification measures that fully uphold environmental, social, human rights, and gender equality standards. It urges consultation on draft European Sustainability Reporting Standards (ESRS), improved quality of corporate governance, legal certainty for businesses, and support for SMEs. The Committee also recommends clear, proportionate due diligence obligations, safeguards for victims’ legal representation, a level playing field across the Single Market, careful handling of the proposed Carbon Border Adjustment Mechanism (CBAM) exemption for small importers, and an annual review of default carbon price values.

On 10^th of September 2025, the European Parliament adopted simplifications to the EU’s Carbon Border Adjustment Mechanism (CBAM) by 617 votes in favour, 18 against and 19 abstentions, as part of the “Omnibus I” package: imports up to 50 tonnes per year per importer will now be exempt (replacing the negligible-value threshold), thereby excluding around 90% of importers while still covering 99% of CO₂ emissions from key sectors such as iron, steel, aluminium, cement and fertilisers. Procedures for the remaining CBAM-covered imports will be streamlined through modifications to authorisation, emissions calculation, verification and financial liability rules, while safeguards and anti-abuse provisions are reinforced. The revised text was sent to the Council and signed off on the 29^th of September 2025.

 

 

EU Waste Directive

On the 26 of September 2025, the European Commission published Directive (EU) 2025/1892, which amends Directive 2008/98/EC on waste. The aim is to significantly reduce food and textile waste across the European Union by 2030.

Under the new rules, textile producers will be responsible for the costs of collecting, sorting, and recycling their products through Extended Producer Responsibility (EPR) schemes, which each country must implement and establish EPR systems for textiles by April 17, 2028. This obligation applies to both EU-based and non-EU companies, including those operating via e-commerce. Microenterprises will have one additional year to comply.

The covered products include clothing, footwear, accessories, blankets, curtains, and household textiles such as bedding and kitchen linens. The legislation also allows Member States to establish EPR schemes for mattresses and encourages addressing fast and ultra-fast fashion practices when defining producers’ financial contributions.

Other specific obligations are:

• Producers must register in a national system and may operate through Producer Responsibility Organisations (PROs).
• Priority will be given to local reuse and fibre-to-fibre recycling.
• Fee modulation. Producer fees will be adjusted based on eco-design criteria such as durability, reparability, and recyclability.
• Fast and ultra-fast fashion practices may be penalised.

Member States will have 20 months to transpose it into national law. Directive will enter into force on October 16, 2025.

 

France

The European Commission released the proposal for the regulation amending Regulation (EU) 2023/956 to simplify and strengthen the Carbon Border Adjustment Mechanism (CBAM) to delegations so they can examine the revised legislative financial and digital statement.  The proposal sets out the framework of the initiative, policy area climate policy, objectives, specific targets (including reducing administrative burden and improving CBAM’s functioning), expected impacts (such as reducing greenhouse gas emissions and carbon leakage, replacing free allocations under the EU ETS, and generating revenues estimated above EUR 2.1 billion by 2030), transitional and definitive implementation periods (with full operation from 1 January 2026), rationale, budget implementation under the EU budget, and the estimated financial and digital impact through 2027.

• The order of 2 September 2025, published in the Official Journal, updates the list of products covered by an accreditation program for the certification of the “Circular Economy Product” label. This measure aims to promote products from the circular economy by facilitating their identification and certification. The covered products are now eligible for a specific accreditation procedure, thereby enhancing transparency and consumer confidence in environmentally friendly products.
• Decree No. 2025-917 of 5 September 2025 amends Decree No. 2018-1043 of 28 November 2018, which established the “Low-Carbon” label. The changes result from a public consultation held from 7 April to 4 May 2025 and update several articles (Art. 1, 1-1, 2, etc.) of the 2018 decree. The decree entered into force on 8 September 2025. The Order of 5 September 2025 establishes the reference framework for the “Bas‑Carbone” label (Low‑Carbon label). It outlines the operational conditions of the label created by the decree of 28 November 2018, including the procedures and criteria for granting this label. This order is set to come into force on 8 September 2025.
• On September 9, 2025, the French government released Decree No. 2025-957, which establishes the methods for calculating and communicating the “environmental cost” for textile products, specifying that any actor — manufacturer, importer, or distributor — who calculates or communicates an environmental cost or environmental impact score for a textile product must comply with the provisions set out. The decree entered into force on October 1, 2025, with regulated information obligations for those placing products on the market. Additionally, on that same date the government issued an Order which complements the decree by detailing the methodology for calculating the environmental cost of textile clothing products. The Order also mandates the signage for displaying environmental costs.
• The Arrêté du 3 septembre 2025 establishes minimum requirements for environmental impact assessments and hazard studies necessary for obtaining environmental authorisations for certain classified installations under French law. It specifies the competencies required for study offices involved in renewable energy projects, detailing the necessary methodologies, documentation quality, and compliance with regulatory standards. The decree also outlines procedures for suspending or withdrawing certifications of study offices that fail to meet these standards, aiming to enhance the quality and efficiency of environmental authorisation processes.
• ADEME published on August 28, 2025, a set of methodological sheets titled Environmental Assessment Methods – M01, focused on the main method M01 “attributional LCA” and its variations. Each sheet provides a detailed analysis of the method, including a general overview, information on the types of indicators, a summary of evaluation elements, a SWOT analysis, and a postface.
• On September 4, 2025, France notified the European Commission of a draft decree establishing financial adjustments for producers incorporating recycled plastic materials. The decree introduces a premium system to incentivize the use of recycled plastics, replacing existing arrangements. The proposed premiums are €450 per tonne for recycled plastic from other extended producer responsibility streams and €550 per tonne for recycled plastic from the same stream. No penalties are introduced, as most existing specifications already penalize recycling disruptors. The mechanism is set to come into force on January 1, 2026.

 

AGEC Law

• The Order of 5 September 2025 establishes the financial contribution rates for producers incorporating recycled plastics into their products, as per the provisions of Article 101 of the Law No. 2020-105 of 10 February 2020 (AGEC Law). This order specifies the modulation of contributions based on the percentage of recycled content used in plastic products. It aims to incentivize the incorporation of recycled materials into plastic products to promote recycling and reduce plastic waste. The order is set to come into force on 8 September 2025.
• The Notice of 5 September 2025 repeals the previous notice concerning the scope of the extended producer responsibility (EPR) scheme for construction products and materials. This repeal is part of the implementation of the AGEC law which aims to expand the EPR framework to include construction products and materials.

 

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

 

Entity	Date	Publication
Textile Exchange	08/2025	In August 2025, Textile Exchange released a new position paper outlining best practice for the responsible use of Life Cycle Assessment (LCA) data in the fashion, textile, and apparel industry. The Transition Pathways article highlights the responsible use of LCA data in the textile sector, emphasizing transparency, consistency, and relevance across a product’s full life cycle. It addresses challenges such as data quality, representativity, system boundaries, and allocation rules, while promoting best practices like documentation, stakeholder engagement, and methodological alignment to strengthen the credibility and usefulness of LCAs in decision-making.
Euratex	08/2025	EURATEX has submitted a response to the European Commission’s consultation on the European Data Union Strategy, advocating that the textile and clothing sector—characterised by many SMEs and complex global value chains—needs streamlined, coherent data regulation. They argue that while the industry produces large volumes of data, much is fragmented or inaccessible under current structures. Their response calls for aligned reporting across legislations, interoperable tools and taxonomies, improved SME access to data infrastructure, and frameworks that accommodate SME realities while preserving lawful international data flows.
US/CA	08/08/2025	California has proposed to list nail products containing triphenyl phosphate (TPhP) as a Priority Product is the California Department of Toxic Substances Control (DTSC). On August 8, 2025, the DTSC initiated a public consultation on a proposed rule to designate nail products containing more than 250 ppm of TPhP as a Priority Product under the state’s Safer Consumer Products (SCP) Regulations. The consultation period is open until 22nd September 2025.
Indonesia	08/08/2025	Indonesia has launched a long-term plastic waste and circular economy strategy (2025–2045) guided by the 9R principles. The country generated 4.22 million tonnes of plastic waste in 2023, with 44% mismanaged, ranking eighth globally, while imports rose in 2022 and the domestic industry reached 7.04 million tonnes in 2024. Key actions include the National Roadmap and Action Plan Circular Economy, existing waste laws, and voluntary Extended Producer Responsibility, though challenges remain with recycling infrastructure, enforcement, awareness, and geography, highlighting the need for binding EPR, better coordination, and stronger investment.
Poland	13/08/2025	In August 2025, Poland’s parliament published a draft of a new Act on Packaging and Packaging Waste, introducing changes to the national extended producer responsibility system. The draft aligns national regulations with EU rules, aims to ensure stable financing for municipal waste management, and sets out the distribution of costs among producers, municipalities, and consumers. The draft is currently under public consultation and inter-ministerial review, with publication in the Journal of Laws expected in the fourth quarter of 2025.
US/ Illinois	15/08/2025	On August 6, 2021, Illinois enacted the PFAS Reduction Act (SB 2516), which initially targeted firefighting foams. On August 15, 2025, the Act was amended through HB 2516 to significantly expand its scope. The amended PFAS Reduction Act in Illinois (HB 2516) expands the original law by redefining “intentionally added PFAS” and prohibiting, beginning January 1, 2032, the sale, offering for sale, or distribution in the state of cosmetics, dental floss, juvenile products, menstrual products, and intimate apparel if they contain intentionally added PFAS (with specified exemptions). It also mandates the Illinois Environmental Protection Agency to report to the General Assembly by August 1, 2027, on reviewing fluoropolymers in consumer products. For violations, the Act allows civil penalties up to $5,000 for a first offence and up to $10,000 for subsequent offences, with enforcement by the Attorney General or the county or state’s attorneys.
HSE UK	18/08/2025	The Health and Safety Executive (HSE), acting as the UK REACH Agency, has launched a six-month public consultation (open until 18 February 2026) to collect views on proposed restrictions on PFAS in firefighting foams, accompanied by an Annex 15 restriction report outlining the scientific analysis and evidence base. The consultation invites input from industry, trade groups, and other stakeholders before proposals are forwarded to the Defra Secretary of State and the Scottish and Welsh Governments to decide whether to enact legal restrictions.
ACS (American Chemical Society)	18/08/2025	Researchers at North Carolina State University (NC State) have developed a method to use cottonseed oil as a safer and more sustainable alternative to formaldehyde and per- and polyfluoroalkyl substances (PFAS) in cotton fabric finishing. The process involves chemically modifying cottonseed oil to create epoxidized cottonseed oil (ECSO), which forms strong chemical bonds with cotton fibres, imparting water resistance and wrinkle resistance to the fabric. This approach offers a bio-based, water-based solution that could replace traditional chemical treatments, benefiting both the environment and human health. The research was presented at the American Chemical Society Fall 2025 meeting.
UKFT	18/08/2025	The UK Fashion & Textile Association (UKFT) has launched its second 2025 Sustainability Survey for fashion and textile firms across the UK, aiming to gather data on sourcing, supply chain practices, innovation, policies, targets, and challenges. The insights will form a foundation for UKFT’s future advocacy, lobbying, and industry-wide efforts to promote sustainable practice. Responses are requested by 15 September 2025, and will be kept confidential, with headline findings shared with participants.
ECHA	20/08/2025	ECHA has published an updated PFAS restriction proposal under the EU’s REACH regulation, building on more than 5,600 comments received during the 2023 public consultation. The revised proposal now covers additional sectors—including printing, sealing, machinery, technical textiles, medical, military, explosives, solvents and catalysts—and suggests possible derogations or conditional uses for critical applications where alternatives are not yet feasible. The two ECHA scientific committees, RAC and SEAC, are currently evaluating the updated dossier, and ECHA aims to deliver its opinions to the European Commission by the end of 2026.
ESMA	20/08/2025	The European Securities and Markets Authority (ESMA) and the European Environment Agency have signed a memorandum of understanding to deepen cooperation in sustainable finance oversight. The agreement aims to integrate environmental data into EU sustainable finance policy enforcement, facilitate information and technical expertise sharing, and conduct joint training and capacity-building. It also envisions coordinating national regulators and environmental authorities across Member States to reduce duplication and strengthen oversight. According to both bodies, the tighter collaboration will help address challenges related to biodiversity, climate change and pollution.
TRIS – Brussels	21/08/2025	The Government of the Brussels-Capital Region has submitted a draft decree to amend its 2016 waste management decree (“Brudalex”) to align with the new Regulation 2023/1542 on batteries and battery waste, replacing the former Directive 2006/66/EC. The draft introduces obligations for battery producers — including registration, authorisation, data reporting, supervision, and fulfilment of extended producer responsibility — while allowing flexibility for Member States in setting administrative procedures. Stakeholders can submit comments in any EU official language until 24 November 2025 (end of the standstill period), with contributions published publicly unless confidentiality is requested.
EU & US	21/08/2025	The United States and the European Union have reached a Framework Agreement on reciprocal, fair, and balanced trade, covering tariff elimination on EU industrial goods, preferential access for U.S. agricultural and seafood products, U.S. tariffs on EU goods, as well as cooperation on autos, steel, aluminium, energy, defence procurement, standards, and sustainability policies. The statement also directly links trade talks to EU regulations. On the CSDDD and CSRD, the EU commits to reducing administrative burdens, reconsidering civil liability and climate-transition obligations, and addressing U.S. concerns about applying these rules to non-EU firms. On the EUDR, the EU pledges to address concerns of U.S. producers, recognising negligible deforestation risk, to avoid undue trade impacts.
US/CA	22/08/2025	California’s Department of Resources Recycling and Recovery (CalRecycle) formally initiated the rulemaking process for permanent regulations under Senate Bill 54, which establishes the Plastic Pollution Prevention and Packaging Producer Responsibility Act and sets minimum content requirements for single-use packaging and single-use plastic food service ware under an extended producer responsibility (EPR) program
EU Commission	25/08/2025	The European Commission has launched a call for evidence to gather feedback on revising the ecodesign requirements for electric motors and variable speed drives. These components are widely used in industrial, building, and household applications, and variable speed drives help optimise energy use under variable loads. The review is the first step to update the existing 2019 rules in line with technological progress and to potentially expand the scope to include material efficiency and circular economy criteria under the Ecodesign for Sustainable Products Regulation (ESPR). The consultation runs until 22 September 2025, and responses will feed into an impact assessment, with the goal of adopting new rules by 2029.
German/Netherlands/Norway/ Denmark /Sweden	25/08/2025	On August 25, 2025, the environmental agencies of Germany, the Netherlands, Norway, Denmark and Sweden announced a significant milestone in limiting PFAS: after reviewing over 5,600 comments, they submitted an updated restriction proposal to ECHA, expanding and refining the original 2023 proposal covering more than 10,000 PFAS substances. The updated documents incorporate new knowledge, introduce eight additional sectors (such as printing, seals, machine parts, military, technical textiles, and industrial uses), and include time-limited exceptions or risk-mitigation conditions where appropriate. ECHA’s scientific committees (RAC and SEAC) are now preparing their evaluations, with conclusions expected to be delivered to the European Commission during 2026, which will ultimately determine the final scope of PFAS restrictions.
TRIS- Poland	28/08/2025	Poland has forwarded to the European Commission a draft regulation titled “Regulation of the Minister for Climate and the Environment on specific rates of product fees for individual products,” dated 28 August 2025, which concerns fiscal measures under the 2015/1535 Directive. The regulation sets fee rates for certain products (including lubricating oils, tyres, and fishing gear containing plastic) in relation to achieving collection, recovery, and recycling targets. It builds upon an earlier 2019 regulation and complies with the authority given in Article 14(4) of the Act of 11 May 2001, now updated by the 2023 amendments, and does not introduce new obligations beyond setting the rates.
TRIS- Austria	29/08/2025	The Austrian Government has notified a draft Compost Ordinance – KompV 2025, with a standstill period ending on 1 December 2025. The ordinance sets out rules for the end-of-waste status of composts and establishes quality requirements for composts and compost soils, updating the original 2001 regulation and allowing reference to existing standards for detailed elements like sampling. No stakeholder contributions have been submitted yet.
European Commission	29/08/2025	On 29 August 2025, the European Commission issued a Call for Evidence for a new initiative titled “Strategic Roadmap for digitalisation and AI in the energy sector,” explaining the political context, outlining four main challenges (data access, fragmentation, energy demand of digital systems, and risks of large-scale AI deployment), and proposing five objectives to guide future action, with a public consultation planned and measures to be monitored over time.
EU Parliament	02/09/2025	The European Commission has proposed an amendment to the European Climate Law to establish a binding Union-wide climate target for 2040, aiming for a net 90% reduction in greenhouse gas emissions compared to 1990 levels. The proposal includes provisions for the potential use of international carbon credits from 2036, capped at 3% of 1990 EU net emissions, to support the 2040 target. The European Parliament’s Environment, Climate and Food Safety Committee (ENVI) is reviewing the proposal, with the Committee on Industry, Research and Energy (ITRE) providing an opinion. The legislative process is ongoing, with discussions and amendments taking place in the coming months.
Spain Government	02/09/2025	On September 1, 2025, Spanish Prime Minister Pedro Sánchez proposed a State Pact to address the Climate Emergency. The plan involves all administrations and aims to establish a coordinated and cooperative approach to tackle climate challenges. The roadmap for this pact includes ten specific commitments, such as creating permanent funds with national and regional economic resources to accelerate reconstruction and recovery efforts in municipalities affected by extreme weather events. The government is set to approve this roadmap in the coming days.
The Swiss Parliament	03/09/2025	Switzerland is considering a standalone regulation to tackle per- and polyfluoroalkyl substances (PFAS), which could differ from EU rules. The Swiss National Council’s committee approved a motion urging the Federal Council to limit PFAS discharges, introduce stricter limits, and ban production where safer alternatives exist. It also supports retroactive compensation for PFAS-related site cleanup under the OTAS environmental fund from 1 April 2025. The initiative aims to strengthen environmental protection while considering economic impacts. In early September, the Swiss National Council’s Committee for the Environment, Spatial Planning and Energy (CEATE-N) approved a revised version of the motion.
US Cotton Trust Protocol	04/09/2025	US Cotton Trust Protocol has launched a field partner programme pilot for the 2025 crop year, which will formally recognise verified regenerative practices and measurable outcomes among growers. The goal is to give brands and retailers access to traceable regenerative U.S. cotton and to enhance value, verification and traceability in sourcing.
US/CA	05/09/2025	On September 5, 2025, the California Air Resources Board (CARB) released draft guidance for corporate climate-related financial risk disclosure, marking a significant step in U.S. climate policy. This guidance stems from Senate Bill 261 (Stern), enacted in 2023, which mandates large companies operating in California to report climate-related financial risks, such as the impact of drought on agriculture or the devaluation of fossil fuel investments. Notably, this positions California as the first state in the U.S. to implement a mandatory corporate climate risk disclosure regime, especially after the Securities and Exchange Commission’s earlier proposal was withdrawn. The guidance outlines that companies must select from existing industry-standard reporting frameworks, providing clarity on compliance requirements ahead of the January 2026 reporting deadline.
ISO & GHG Protocol	09/09/2025	The International Organization for Standardization (ISO) and the Greenhouse Gas Protocol (GHG Protocol) announced a strategic partnership to harmonize their greenhouse gas (GHG) standards and co-develop new standards for GHG emissions accounting and reporting. The partnership also includes the development of a joint product carbon footprint standard to address the growing demand for granular data across value chains. The goal is to reduce fragmentation in GHG accounting, simplify processes for companies, enhance consistency for policymakers, and reduce reporting burdens, thereby accelerating progress towards decarbonization. This initiative aligns with recent calls for harmonization by both government and industry stakeholders.
EU Commission	09/09/2025	The European Commission’s Proposal COM/2025/467 sets out a Council Decision to terminate the Voluntary Partnership Agreement (VPA) between the EU and the Republic of Liberia on Forest Law Enforcement, Governance and Trade in timber products. It notes that although the VPA entered into force on 1 December 2013, the goal of establishing and operationalising a FLEGT licensing scheme has not been achieved, and under Article 29 of the VPA either party may terminate it with written notice, with the Agreement ceasing to apply 12 months after notification. The proposal approves the termination on behalf of the EU, and stipulates that the decision enters into force the day after its publication in the Official Journal.
EU Commission	09/09/2025	The Commission Implementing Decision (EU) 2025/1785 of 9 September 2025 updates the list of harmonised standards for ride-on toys (wave rollers) under Directive 2009/48/EC on toy safety, specifying which technical standards manufacturers, importers, and distributors can rely on to demonstrate compliance with EU safety requirements. The amendment clarifies testing methods, safety limits, and conformity assessment procedures to ensure consistent safety enforcement across the EU market for these toys.
EU Commission	09/09/2025	The European Commission is consulting stakeholders on the inclusion of medium-chain chlorinated paraffins (MCCPs) in the Stockholm Convention on Persistent Organic Pollutants (POPs). This initiative aims to assess the risks posed by MCCPs, which are used in various applications such as plasticizers and flame retardants, and to evaluate the need for international regulatory measures to reduce their environmental and health impacts. The consultation seeks input from industry, environmental groups, and other interested parties to inform the Commission’s position on this matter.
Council of the EU	10/09/2025	On 10 September 2025, the Council adopted its first-reading position on a Regulation to prevent plastic pellet losses and reduce microplastic pollution, setting binding duties for all supply chain actors to prevent, contain, report and clean up spills, register facilities, prepare risk management plans, label pellets, and ensure oversight and penalties of up to 3 % of annual turnover, with obligations varying by enterprise size.
TRIS-Finland	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.
Council of EU	18/09/2025	On 18 September 2025, the EU approved a statement of intent for its post-2030 Nationally Determined Contribution under the Paris Agreement, targeting a 66.25–72.5% greenhouse gas reduction by 2035 compared to 1990 levels. The EU reaffirmed its commitment to limiting global warming to 1.5°C and confirmed it is on track to meet its 2030 target of a 55% reduction. The statement will be shared with the UNFCCC but is not the official NDC. Additionally, the EU Environment Council discussed the proposed European Climate Law amendment aiming for a 90% greenhouse gas reduction by 2040 compared to 1990. Ministers reviewed progress, addressed flexibilities for member states, and highlighted the role of international carbon credits and natural carbon sinks in achieving the target, reaffirming the importance of a robust framework toward climate neutrality.

 

 

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