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.
Last updated – December 4, 2025
Postponements and Foreseen Amendments
- Batteries Regulation
- Carbon Border Adjustment Mechanism (CBAM) Regulation
- Chemicals Omnibus
- Construction Products Regulation (Revision)
- Corporate Sustainability Due Diligence Directive (CSDDD)
- Corporate Sustainability Reporting Directive (CSRD)
- Deforestation-free Products Regulation (EUDR)
- Digitalization and Alignment of Common Specifications
- Ecodesign for Sustainable Products Regulation (ESPR)
- Energy Efficiency of Buildings (EPBD) Directive
- Environmental Omnibus
- EU Emissions Trading System (EU ETS) 2
- Extension of Certain Mitigating Measures Available for Small and Medium-sized Enterprises to Small Mid-cap Enterprises and Further Simplifying Measures
- 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
*Status Update*
Regulation (EU) 2025/1561 entered into force on 31 July 2025, postponing due diligence obligations by one year (i.e., 18 Aug. 2027) and delaying the adoption of due diligence guidelines to 26 July 2026.
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*
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
New! *Adopted*
Following its publication in the EU Official Journal on October 17, 2025 the amendment to the CBAM Regulation entered into force on October 20, 2025.
Implementing Acts
Important detailed rules to be adopted by commission.
*Under discussion*
Impact of Omnibus Initiative on calendar unknown.
Chemicals Omnibus
Key Obligations
On 8 July 2025, the Commission presented an Action Plan for the Chemicals Industry to strengthen competitiveness, support innovation and decarbonization, as well as address high energy costs and global competition. The package includes a sixth Simplification Omnibus (streamlining rules on CLP, cosmetics and fertilizing products), as well as a proposal for an ECHA Basic Regulation to reinforce the agency’s governance and resources. The Action Plan also reaffirms the forthcoming PFAS restriction, with limited exemptions for critical uses.
Entry Into Force
TBC
Postponement
Not applicable.
Amendment
Yes – includes targeted amendments through the Simplification Omnibus.
*Status Update*
In early November, the council endorsed its General Approach, formally establishing its negotiating mandate on the Chemicals Simplification Proposal. Trilogues are expected to start once the European Parliament adopts its position. The European Parliament has now confirmed its internal timeline for examining the proposal. Both the Internal Market and Consumer Protection (IMCO) and Environment, Public Health and Food Safety (ENVI) Committees have until 18 December 2025 to issue their draft reports. The deadline for submitting amendments is set for 3 February 2026, with a committee vote scheduled for late March 2026.
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*
On 13 November 2025, the European Parliament approved the report and authorised the opening of trilogue negotiations. The council had already agreed on its negotiating mandate on 23 June 2025. The first trilogue took place on 18 November 2025, with further debriefs scheduled in early December. A provisional agreement is expected to be finalised by the end of the year.
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*
On 13 November 2025, the European Parliament approved the report and authorised the opening of trilogue negotiations. The council had already agreed on its negotiating mandate on 23 June 2025. The first trilogue took place on 18 November 2025, with further debriefs scheduled in early December. A provisional agreement is expected to be finalised by the end of the year.
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.
New! Amendment
A newly proposed regulation introduces simplification measures for micro and small primary operators and grants companies a grace period ending on June 30, 2026 for non-SME operators and traders, and on December 30, 2026 for certain micro and small undertakings, effectively postponing the EUDR’s application for these operators to December 30, 2026.
*Status Update*
On 19 November 2025, the council endorsed its negotiating position on the simplification proposal, supporting a 12-month postponement to 30 December 2026, an extended deadline to 30 June 2027 for micro- and small-operators, a simplified regime for these operators and a simplification review by 30 April 2026. The European Parliament adopted its negotiating position on 26 November 2025, broadly aligning with these elements.
With both co-legislators having now established their positions, the file returns to the ENVI Committee for the launch of trilogue negotiations. The first trilogue is scheduled for 4 December, and, given the close alignment of the two mandates, may be the only one. Negotiators aim to reach a swift agreement so that the final text can be endorsed by environment ministers and the European Parliament during their respective meetings on 16 December 2025
Implementing Acts
Several implementing and delegated acts to be adopted to enable implementation.
*Under discussion*
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.
*Status Update*
The Council formally adopted its negotiating position on September 24, 2025. At the European Parliament, discussions are ongoing, with a plenary vote currently anticipated in March 2026.
Implementing Acts
N/A
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*
NEW! Environmental Omnibus
Key Obligations
The Commission announced that it will present an Environmental Omnibus as part of its forthcoming Chemicals Industry Action Plan. The Environmental Omnibus will focus on simplifying environmental legislation, particularly in the areas of the circular economy, waste management and industrial emissions.
The Commission launched a public consultation, which closed on 10 September 2025. The consultation garnered an unprecedented 119,543 comments from citizens, companies, NGOs, and other stakeholders on simplifying environmental legislation, particularly in the areas of waste management and industrial emissions.
Entry Into Force
TBC
Postponement
Not applicable.
Amendment
*Status Update*
The European Commission is currently assessing the feedback received through the public consultation and is preparing its legislative proposal. Presentation of the proposal is tentatively planned for 3 December 2025, although this timing may still be subject to change.
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.
*Status Update*
On 27 November 2025, the European Commission presented a proposal to amend the rules governing the Market Stability Reserve for the new EU ETS 2 system. The initiative aims to enable earlier operation of the reserve ahead of the full launch of EU ETS 2, and to strengthen its ability to stabilise the market.
Implementing Acts
Secondary legislation expected to be adopted throughout 2025.
*Under discussion*
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.
*Status Update*
The Council adopted its negotiating mandate on September 24, 2025. Interinstitutional negotiations (trilogues) may commence once the European Parliament establishes its position, with internal discussions still ongoing.
Implementing Acts
N/A
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
*Status Update*
On 30 October, the European Chemicals Agency (ECHA) presented details on the forthcoming consultation for the Committee for Socio-economic Analysis (SEAC) draft opinion on the proposed PFAS restriction. The consultation is expected to open in March 2026, following SEAC’s agreement on a draft opinion. ECHA confirmed that the SEAC assessment will cover only the 14 sectors, and applications identified in the original restriction proposal.
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
*Status Update*
Work on the revision of REACH is progressing within the European Commission. Following the negative opinion issued by the Regulatory Scrutiny Board on the draft impact assessment earlier this autumn, the commission has been updating and refining the assessment. The revised impact assessment is expected to be finalised in the coming weeks. Provided it receives a favourable opinion, the commission plans to present the long-awaited proposal for the REACH revision in the first quarter of 2026.
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, More Than One Constituent Substances (MOCS), and allows digital labels under certain conditions.
Entry Into Force
Entered into force on December 10, 2024.
Postponement
*Status Update*
On 17 November 2025, the General Affairs Council formally adopted the regulation, amending Regulation (EU) 2024/2865 concerning the dates of application and transitional provisions under the LP framework. With the council’s adoption now complete, the amending regulation can proceed to publication in the Official Journal of the EU, after which it will enter into force in accordance with its terms.
Amendment
*Ongoing as part of the Chemical Omnibus package*
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*
At the end of November, the Council Working Party on the Environment was debriefed by the presidency on the state of play of the Green Claims Directive. Despite continued efforts, no majority has yet emerged within the council to support a revised negotiating mandate. As a result, discussions among member states remain at a standstill, and interinstitutional negotiations (trilogues) cannot resume until the council is able to re-establish a unified position.
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*