The European Commission, in this new mandate, has initiated a comprehensive legislative review aimed at simplifying key regulatory initiatives that were part of the EU Green Deal.
This simplification effort seeks to streamline regulatory obligations, reduce administrative burdens, and enhance legal clarity while maintaining the EU’s commitment to sustainability and environmental protection.
This document tracks developments on key sustainability-related legislative measures that are subject to revision or postponement, or for which secondary legislation is set to be adopted to implement the new rules.
For further information or legal guidance regarding any of the legislative measures outlined below, please do not hesitate to contact our team of specialized lawyers and advisers.
Postponements and Foreseen Amendments
- Batteries Regulation
- Extension of Certain Mitigating Measures Available for Small and Medium-sized Enterprises to Small Mid-cap Enterprises and Further Simplifying Measures
- Digitalization and Alignment of Common Specifications
- Carbon Border Adjustment Mechanism (CBAM) Regulation
- Construction Products Regulation (Revision)
- Corporate Sustainability Due Diligence Directive (CSDDD)
- Corporate Sustainability Reporting Directive (CSRD)
- Deforestation-free Products Regulation (EUDR)
- Ecodesign for Sustainable Products Regulation (ESPR)
- Energy Efficiency of Buildings (EPBD) Directive
- EU Emissions Trading System (EU ETS) 2
- Forced Labor Regulation
- FuelEU Maritime Regulation
- Net Zero Industry Act (NZIA)
- Packaging and Packaging Waste Regulation (PPWR)
- Per- and Polyfluoroalkyl Substances (PFAS) Restriction Proposal
- Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Revision
- Revision of the Classification, Labeling and Packaging (CLP) Regulation
- Substantiating Green Claims Directive
- Taxonomy Regulation
Batteries Regulation
Key Obligations
Sustainability, performance, due diligence and recyclability requirements for batteries.
Entry Into Force
Applicable since February 2024.
Postponement
Proposal to postpone the start date for due diligence obligations by one year, to August 18, 2027, and the adoption of due diligence guidelines to July 26, 2026 (previously February 18, 2025).
*Under discussion*
Amendment
Postponement of due diligence obligations as part of Omnibus Package IV.
Implementing Acts
Significant number of implementing and delegated acts to be adopted to detail technical requirements.
*Under discussion*
Commission was due to publish guidelines on due diligence in February 2025.
*Delayed*
Extension of Certain Mitigating Measures Available for Small and Medium-sized Enterprises to Small Mid-cap Enterprises and Further Simplifying Measures
Key Obligations
Simplification measures spanning various regulatory frameworks, specifically aimed at small mid-cap enterprises, for which a definition is being introduced.
Entry Into Force
*Under discussion*
Postponement
N/A
Amendment
The Simplification Package, part of Omnibus Package IV, consists of a proposal for a directive, a proposal for a regulation and a recommendation.
Implementing Acts
N/A
Digitalization and Alignment of Common Specifications
Key Obligations
Facilitate information submission and distribution for companies by allowing them to use digital formats for declarations of conformity, instructions for use and other required documentation.
Entry Into Force
*Under discussion*
Postponement
N/A
Amendment
The Simplification Package, part of Omnibus Package IV, consists of a proposal for a directive with annex and a proposal for a regulation with annex.
Implementing Acts
N/A
Carbon Border Adjustment Mechanism (CBAM) Regulation
Key Obligations
Importers to measure, report, and account for the carbon content of certain goods imported in the EU.
Entry Into Force
Transitional phase since October 2023.
Full regime starting 2026.
Postponement
No postponement of entry into force of mechanism.
Postponement proposals on some obligations (CBAM certificates purchase, by one year).
(Omnibus Package I).
*Under discussion*
Amendment
Simplification Amendments (with annex).
(Omnibus Package I).
*Under discussion*
*Status Update*
Provisional trilogue agreement reached by the co-legislators on 18 June.
EU Parliament’s ENVI Committee approved the text on 3 July 2025.
Full EU Parliament and Council must still endorse the text. Final vote expected in September.
Implementing Acts
Important detailed rules to be adopted by commission.
*Under discussion*
Impact of Omnibus Initiative on calendar unknown.
Construction Products Regulation (Revision)
Key Obligations
Modernize and simplify the rules, improve enforcement and market surveillance, and align the framework with the EU’s sustainability goals.
Entry Into Force
Entered into force on November 27, 2024.
Postponement
N/A
Amendment
N/A
Implementing Acts
Secondary legislation expected to be adopted throughout 2025.
*Under discussion*
Corporate Sustainability Due Diligence Directive (CSDDD)
Key Obligations
Mandatory due diligence framework on environmental, social, and governance (ESG) in supply chains.
Entry Into Force
Supposed to enter into force 2027.
Postponement
Postponement of transposition deadline to 2027 (one year).
*Adopted*
Postponement of first phase of implementation (largest companies) to 2028 (one year).
*Adopted*
Amendment
Simplification amendments proposed.
(Omnibus Package I).
*Under discussion*
*Status Update*
Council agreed on 23 June 2025 on negotiation mandate with the EU Parliament. At EU Parliament level, amendments were accepted until 27 June, with discussion scheduled for mid-July and a committee vote planned for 13 October 2025.
Informal negotiations for a first reading agreement expected to begin October or November 2025.
Implementing Acts
Implementing acts to detail due diligence requirements.
Corporate Sustainability Reporting Directive (CSRD)
Key Obligations
ESG reporting obligations.
Entry Into Force
Tiered entry into force from 2024 to 2028.
Postponement
Postponement of two years for companies that have not yet begun reporting, (Omnibus Package I).
*Adopted*
Amendment
Simplification amendments proposed.
(Omnibus Package I).
*Under discussion*
*Status Update*
Council agreed on 23 June 2025 on negotiation mandate with the EU Parliament. At EU Parliament level, amendments were accepted until 27 June, with discussion scheduled for mid-July and a committee vote planned for 13 October 2025.
Informal negotiations for a first reading agreement expected to begin October or November 2025.
Implementing Acts
Detailed rules still to be adopted by Commission.
Transposition by EU Member States.
*Ongoing*
Deforestation-free Products Regulation (EUDR)
Key Obligations
Due diligence obligations to ensure that imported goods are deforestation free.
Entry Into Force
Was supposed to enter into force on December 31, 2024.
Postponement
Postponed to December 31, 2025 (one year).
*Adopted*
Amendment
Proposed amends dismissed in fall 2024.
*Dismissed*
No further amendment so far.
Implementing Acts
Several implementing and delegated acts to be adopted to enable implementation.
*Under discussion*
Ecodesign for Sustainable Products Regulation (ESPR)
Key Obligations
Introduces ecodesign requirements for certain selected products, including digital product passports and sustainability criteria.
Entry Into Force
Entered into force in July 2024.
Postponement
Not so far.
Amendment
Not so far.
Implementing Acts
Implementing acts to define the products in scope.
First official selection published on April 15.
*Under discussion*
Energy Efficiency of Buildings (EPBD) Directive
Key Obligations
Promote the enhancement of buildings’ energy performance, while also driving the reduction of greenhouse gas emissions from buildings.
Entry Into Force
Entered into force on May 28, 2024.
Postponement
N/A
Amendment
N/A
Implementing Acts
Secondary legislation expected to be adopted throughout 2025.
*Under discussion*
EU Emissions Trading System (EU ETS) 2
Key Obligations
Extend the application of emissions trading to maritime and road transport, and buildings.
Entry Into Force
Entered into force on June 5, 2023.
Postponement
N/A
Amendment
Revision scheduled for the Q3 of 2026.
Implementing Acts
Secondary legislation expected to be adopted throughout 2025.
*Under discussion*
Forced Labor Regulation
Key Obligations
Due diligence obligations to ensure that imported goods are not produced with forced labor.
Entry Into Force
Entered into force in December 2024.
Controls to start from December 2027.
Postponement
Not so far.
Amendment
Not so far.
Implementing Acts
Some secondary legislation to be adopted by Commission.
FuelEU Maritime Regulation
Key Obligations
Sets uniform rules to limit the greenhouse gas intensity of energy used by certain large ships on EU and non-EU voyages (with specific limitations).
Entry Into Force
Entered into force on October 12, 2023.
Postponement
N/A
Amendment
N/A
Implementing Acts
Secondary legislation expected to be adopted throughout 2025.
*Under discussion*
Net Zero Industry Act (NZIA)
Key Obligations
Promotes the development of green technologies identified as “net-zero technologies” in the regulation, by facilitating access to funding and accelerating permitting procedures.
Entry Into Force
Entered into force on June 29, 2024.
Postponement
N/A
Amendment
N/A
Implementing Acts
Secondary legislation expected to be adopted throughout 2025.
*Under discussion*
Packaging and Packaging Waste Regulation (PPWR)
Key Obligations
Requirements on packaging sustainability, waste reduction, recycling and reporting affecting packaging materials and waste management.
Entry Into Force
Entered into force in February 2025.
General application date set for August 12, 2026.
Postponement
Not so far.
Amendment
Not so far.
Implementing Acts
Secondary legislation expected to be adopted throughout 2025.
*Under discussion*
Per- and Polyfluoroalkyl Substances (PFAS) Restriction Proposal
Key Obligations
Proposes to restrict or ban the manufacture, import and use of PFAS.
Entry Into Force
Decision-making process ongoing (European Chemicals Agency (ECHA) committees).
Postponement
Commission contemplates a legislative proposal to restrict PFAS in consumer products.
Amendment
N/A
Implementing Acts
N/A
Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Revision
Key Obligations
Introduces stricter and more efficient rules on the use and restriction of harmful substances, and simplifies procedures, particularly by shortening the duration of authorization and restriction processes.
Entry Into Force
Legislative proposal expected for Q4 2025.
Postponement
N/A
Amendment
N/A
Implementing Acts
N/A
Revision of the Classification, Labeling and Packaging (CLP) Regulation
Key Obligations
Simplifies hazard labeling, bans misleading "green" ads, and extends rules to online sales. It introduces provisions for refillables, MOCS, and allows digital labels under certain conditions.
Entry Into Force
Entered into force on December 10, 2024.
Postponement
Not so far.
Amendment
Not so far.
Implementing Acts
The Commission is empowered to adopt ad hoc delegated acts under certain articles of the law.
Substantiating Green Claims Directive
Key Obligations
Requires companies to substantiate any environmental claims made in marketing and advertising, aiming to curb greenwashing.
Entry Into Force
Decision-making process ongoing (legislative process).
*Status Update*
In June, EU Commission signaled plans to withdraw the file, causing the Council to pause. Danish Presidency will lead further talks from 1 July. Trilogues will only resume if the Council reaches consensus; otherwise, the proposal remains blocked.
Postponement
Not so far.
Amendment
Not so far.
Implementing Acts
N/A
Taxonomy Regulation
Key Obligations
Criteria to define environmentally sustainable economic activities; associated reporting obligations.
Entry Into Force
Entered into force in 2022.
Updates are ongoing.
Postponement
No postponement proposal.
Amendment
Simplification amendments proposed.
(Omnibus Package I).
*Under discussion*
Implementing Acts
Draft delegated act amending the Taxonomy Disclosures and the Taxonomy Climate and Environmental delegated acts subject to public consultation.
*Under discussion*