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 – May 11, 2026
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
Automotive Omnibus |
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Key Obligations | On 16 December 2025, the Commission presented the Automotive Omnibus as part of the Automotive Package supporting the transition to clean mobility. The Omnibus consists mainly of a proposal for a Regulation (COM(2025) 993) amending Regulations (EC) No 561/2006, (EU) 2018/858, (EU) 2019/2144 and (EU) 2024/1257 to simplify technical requirements, testing procedures and compliance obligations for motor vehicles, while repealing Regulation (EU) No 540/2014 and Council Directive 70/157/EEC. It is complemented by a linked Directive proposal (COM(2025) 999) amending Directive 92/6/EEC to exempt certain N2 electric vehicles from speed limitation requirements, and by a Commission Staff Working Document (SWD(2025) 1056) setting out the technical and economic rationale. |
Entry Into Force | TBC |
Postponement | Not applicable. |
Amendment | *Status Update* |
Batteries Regulation |
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Key Obligations | Sustainability, performance, due diligence and recyclability requirements for batteries. |
Entry Into Force | Applicable since February 2024. |
Postponement | *Status Update* |
Amendment | Postponement of due diligence obligations as part of Omnibus Package IV. *New Proposal* A separate proposal adopted on the same date provides for the temporary suspension of the rules on the appointment of an authorised representative for extended producer responsibility for batteries and packaging. |
Implementing Acts | Significant number of implementing and delegated acts to be adopted to detail technical requirements. Commission was due to publish guidelines on due diligence in February 2025. |
Carbon Border Adjustment Mechanism (CBAM) Regulation |
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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 on some obligations (CBAM certificates purchase, by one year). *Adopted* |
Amendment | *Adopted* Following its publication in the EU Official Journal on 17 October 2025 the amendment to the CBAM Regulation entered into force on 20 October 2025. |
Implementing Acts | *Status Update* The adopted acts lay down the technical, procedural and enforcement rules for CBAM, including the calculation of embedded emissions), and default values, adjustments reflecting EU ETS free allocation, certificate pricing, verification of embedded emissions, and accreditation of verifiers, the conditions for authorized CBAM declarants, as well as the functioning of the CBAM Registry, including data protection and customs data exchanges. |
Chemicals Omnibus |
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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 | *Status Update* |
Construction Products Regulation (Revision) |
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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 | Not applicable. |
Amendment | Not applicable. |
Implementing Acts | Secondary legislation expected to be adopted throughout 2026. |
Corporate Sustainability Due Diligence Directive (CSDDD) |
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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). Postponement of first phase of implementation (largest companies) to 2028 (one year). |
Amendment | Simplification amendments adopted (Omnibus Package I). *Status Update* Due diligence requirements apply to companies exceeding 5,000 employees and €1.5 billion net turnover, including certain franchising arrangements and third-country companies meeting specific EU turnover thresholds. The Directive will enter into force on 18 March 2026. Member States must transpose the CSDDD amendments by 26 July 2028. |
Implementing Acts | Implementing acts to detail due diligence requirements. |
Corporate Sustainability Reporting Directive (CSRD) |
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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). |
Amendment | Simplification amendments adopted (Omnibus Package I). *Status Update* Under Directive 2013/34/EU as amended, mandatory sustainability reporting applies to undertakings exceeding 1,000 employees and €450 million net turnover. The Directive will enter into force on 18 March 2026. Member States must transpose the CSRD amendments by 19 March 2027. |
Implementing Acts | The European Commission issued two draft Delegated Acts one on the revised European Sustainability Reporting Standards, and another one on the Sustainability Reporting Standards for voluntary use. Both are now under a public consultation which is open until 3 June. |
Deforestation-free Products Regulation (EUDR) |
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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). |
Amendment | Postponement and Simplification Regulation Adopted in December 2025, Regulation (EU) 2025/2650 grants an additional one-year postponement of the EUDR’s application for all operators until 30 December 2026, with a further six-month grace period for micro and small operators until 30 June 2027. Further, it simplifies due diligence and traceability obligations, removes due diligence statement obligations for downstream operators and traders, introduces a simplified declaration for micro and small primary operators, and requires the Commission to carry out a simplification review by 30 April 2026. NEW ! Simplification Package The European Commission issued on 4 May 2026 its anticipated EUDR simplification package, comprising of a Report on the simplification review, revised Guidance and FAQs on the interpretation of the EUDR and a draft Delegated Regulation amending the scope of application to exclude product such as leather and retreaded tyres. A draft Implementing Regulation on amending the functionalities of the IT system will be issued in the coming weeks. |
Implementing Acts | A draft Delegated Regulation amending the scope of application of the EUDR is now put for public consultation until 1 June 2026. A draft Implementing Regulation on amending the functionalities of the IT system is pending publication. |
Digitalization and Alignment of Common Specifications |
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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 | Not applicable. |
Amendment | *Status Update* The Council adopted its negotiating mandate on 24 September 2025. In the European Parliament, the IMCO Committee adopted its amendments on 27 January 2026, clarifying that the Commission’s power to adopt common specifications should remain temporary and limited in time, and strengthening parliamentary oversight. The first trilogue meeting took place on 15 April 2026, after which the Council’s Antici Group on Simplification met on 27 April 2026 to debrief on the outcome of the first trilogue meeting. Further meetings will be scheduled in the coming months. |
Implementing Acts | Not applicable. |
Ecodesign for Sustainable Products Regulation (ESPR) |
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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 | *Status Update* The Commission’s Joint Research Centre (‘JRC’) is finalising its preparatory study for the elaboration of ecodesign criteria for textile products. MEPs from the Greens and S&D have already expressed worries that the study does not address the need to promote materials from renewable sources but instead favour recycled content. |
Energy Efficiency of Buildings (EPBD) Directive |
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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 | Not applicable. |
Amendment | Not applicable. |
Implementing Acts | Secondary legislation adoption ongoing. *Status Update* The European Parliament requested an extension of the scrutiny period on 26 January 2026. The deadline for objections is now set for 16 April 2026. If no objection is raised by the European Parliament or the Council within the extended scrutiny period, the Delegated Regulation will be published in the Official Journal and enter into force twenty days thereafter. |
Environmental Omnibus |
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Key Obligations | On 10 December 2025, the Commission presented the Environmental Omnibus (VIII) in the form of a Communication (COM(2025) 980 final), accompanied by six legislative proposals covering environmental assessments, industrial emissions, waste legislation, extended producer responsibility schemes, batteries and packaging, and the INSPIRE Directive. |
Entry Into Force | TBC |
Postponement | Not applicable. |
Amendment | *Status Update* France has issued a note opposing the Commission’s proposal to suspend the obligation to appoint an authorized representative in each Member State that is currently applicable under the PPWR and the SUPD. This objection initially supported by Austria, Belgium, Bulgaria, Estonia, Slovakia, Slovenia and Spain is now backed up by a majority of the Member States. The Commission foresees an adoption of all initiatives in the package by the end of 2026. |
EU Emissions Trading System (EU ETS) 2 |
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Key Obligations | Extend the application of emissions trading to maritime and road transport, and buildings. |
Entry Into Force | Entered into force on 5 June 2023. |
Postponement | Not applicable. |
Amendment | Revision scheduled for the Q3 of 2026. *Status Update* The European Parliament adopted changes to the Market Stability Reserve, which is governing the supply of ETS2 trading permits on 29 April. |
Implementing Acts | Secondary legislation expected to be adopted throughout 2025 and 2026 |
Extension of Certain Mitigating Measures Available for Small and Medium-sized Enterprises to Small Mid-cap Enterprises and Further Simplifying Measures |
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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 | Not applicable. |
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* |
Implementing Acts | Not applicable. |
Forced Labor Regulation |
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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 | Commission Implementing Regulation (EU) 2026/903 on the authorities’ information and communication system was published on 27 April 2026. |
FuelEU Maritime Regulation |
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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 | Not applicable. |
Amendment | Not applicable. |
Implementing Acts | Secondary legislation expected to be adopted throughout 2026. |
Net Zero Industry Act (NZIA) |
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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 | Not applicable. |
Amendment | Not applicable. |
Implementing Acts | Secondary legislation expected to be adopted throughout 2026. |
Packaging and Packaging Waste Regulation (PPWR) |
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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. *Status Update* On 30 March 2026, the Commission issued the PPWR Notice and FAQ. |
Postponement | Not so far. |
Amendment | Not so far. |
Implementing Acts | *Status Update* In parallel, secondary legislation under the PPWR is progressing, including the adoption on 25 February 2026 of a Delegated Decision exempting certain pallet wrappings and straps from the 100% reuse obligations, currently under scrutiny by the co-legislators. |
Per- and Polyfluoroalkyl Substances (PFAS) Restriction Proposal |
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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* Commissioner Roswall on the other hand announced in the context of the meeting with the European Parliament’s ENVI Committee that she hopes the Commission’s proposal on the restriction will be issued by the end of the year. |
Implementing Acts | Not applicable. |
Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Revision |
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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 | Not applicable. |
Amendment | *Status Update* |
Implementing Acts | Not applicable. |
Revision of the Classification, Labeling and Packaging (CLP) Regulation |
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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* |
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 |
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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* |
Postponement | Not so far. |
Amendment | Not so far. |
Implementing Acts | Not applicable. |
Taxonomy Regulation |
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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 adopted under Directive (EU) 2026/470, was published in the Official Journal on 26 February 2026. The European Commission issued on 28 April 2026 a Communication on Better Regulation and Enforcement, announcing the intention to simplify the Taxonomy’s Technical Screening criteria and streamlining taxonomy disclosures. |
Implementing Acts | Commission Delegated Regulation (EU) 2026/73 simplifying parts of the Taxonomy regime was published in the Official Journal of the EU on 8 January 2026. On 18 March 2026, the Commission published two draft Delegated Regulations reviewing the EU taxonomy climate delegated act and the EU taxonomy environmental delegated act both placed for public consultation until 14 April 2026. |