EU Green Deal Simplification Tracker

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

Yes, includes targeted amendments and repeals across several existing automotive Regulations and Directives.

*Status Update*
The Automotive Omnibus was adopted and presented by the Commission on 16 December 2025 and identified as a legislative priority for 2026 in the Joint Declaration of the European Parliament, the Council and the Commission. Substantive examination of the proposal in the European Parliament and the Council is expected to begin in early 2026, in line with the Ordinary Legislative Procedure.

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.

*New Proposal*
Simplification proposal issued as part of the Environmental Omnibus Package (Omnibus VIII) on 10 December 2025, targeting the role of the different actors in the supply chain, obligations relating to the presence of hazardous substances and reporting obligations. Another proposal suspends the application of rules on the appointment of authorized representatives.

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*

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

*Status Update*
On 17 December 2025, the Commission adopted a package of eight implementing acts and one delegated act completing the legal framework for the definitive CBAM phase starting on 1 January 2026. The adopted acts set out the technical, procedural and enforcement rules for CBAM, including the calculation of embedded emissions and default values, adjustments for EU ETS free allocation, CBAM certificate pricing, verification and accreditation of verifiers, authorised CBAM declarant conditions, the functioning of the CBAM Registry (including data protection), and customs data exchanges.
In parallel, the Commission tabled a proposal to amend Regulation (EU) 2023/956 to extend CBAM to additional downstream products and strengthen anti-circumvention rules. This proposal is subject to the ordinary legislative procedure and does not affect the entry into force of the adopted implementing and delegated acts.

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*
The Council issued its negotiation mandate on 6 November 2025, significantly narrowing the proposed simplification of the Cosmetics Regulation, while retaining more limited adjustments to the CLP amendments. The European Parliament has confirmed its examination timeline, with IMCO and ENVI due to issue draft reports by 18 December. ENVI will lead on CLP and cosmetics, while IMCO will focus on fertilising products. The deadline for amendments is 3 February, with committee consideration in late January and a vote currently envisaged for mid-March 2026.

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 2025.
*Under discussion*

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*
The proposal recalibrates corporate sustainability obligations by separately adjusting the scope of the CSRD and the CSDDD. CSRD reporting obligations would apply primarily to undertakings exceeding 1,000 employees and €450 million net turnover, while CSDDD due diligence obligations would be limited to companies with more than 5,000 employees and €1.5 billion net turnover.
Following trialogue meetings on 18 November and 8 December 2025, the co-legislators reached a provisional agreement, which was endorsed by COREPER II on 10 December 2025, approved by the JURI Committee on 11 December 2025, and adopted by the European Parliament in plenary on 16 December 2025. The text is now pending formal adoption by the Council and subsequent publication in the Official Journal.

Implementing Acts

Implementing acts to detail due diligence requirements.

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*
The proposal recalibrates corporate sustainability obligations by separately adjusting the scope of the CSRD and the CSDDD. CSRD reporting obligations would apply primarily to undertakings exceeding 1,000 employees and €450 million net turnover, while CSDDD due diligence obligations would be limited to companies with more than 5,000 employees and €1.5 billion net turnover.
Following trialogue meetings on 18 November and 8 December 2025, the co-legislators reached a provisional agreement, which was endorsed by COREPER II on 10 December 2025, approved by the JURI Committee on 11 December 2025, and adopted by the European Parliament in plenary on 16 December 2025. The text is now pending formal adoption by the Council and subsequent publication in the Official Journal.

Implementing Acts

Detailed rules still to be adopted by Commission.

Transposition by EU Member States.
*Ongoing*

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! 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, excludes certain printed products (e.g. books and newspapers) from scope, and requires the Commission to carry out a simplification review by 30 April 2026.
The Council formally adopted the European Parliament’s first-reading position on 18 December 2025, completing the legislative process; the Regulation was published in the Official Journal on 23 December 2025 and will enter into force on 26 December 2025.

Implementing Acts

Several implementing and delegated acts to be adopted to enable implementation.
*Under discussion*

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

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. In the European Parliament, the IMCO Committee examined compromise amendments on 3 December 2025, with broad convergence emerging on limiting the Commission’s power to adopt common specifications, introducing a right of objection for Parliament, and ensuring such specifications remain a last-resort and temporary measure. A vote in the IMCO Committee is now scheduled for 27 January 2026, with a plenary vote still tentatively anticipated in March 2026.

Implementing Acts

Not applicable.

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*

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 expected to be adopted throughout 2025.
*Under discussion*

*Status Update*
In December 2025, the Commission adopted a Delegated Regulation establishing a Union framework for the national calculation of the life-cycle Global Warming Potential (GWP) of buildings, pursuant to the recast EPBD. The Delegated Regulation was adopted on 16 December 2025 and replaces Annex III of Directive (EU) 2024/1275. It has been transmitted to the European Parliament and the Council for scrutiny, with a deadline for objections set to 16 February 2026, and will enter into force twenty days after publication in the Official Journal if no objections are raised.

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*
Environment ministers discussed the Communication at the Environment Council on 16 December 2025, broadly supporting the objective of simplification while raising concerns regarding legal certainty, subsidiarity and the risk of weakening environmental standards. The Communication has been transmitted to the European Parliament and the Council, which may respond through the adoption of a Resolution or Conclusions.

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

Not applicable.

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*

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*
The Council adopted its negotiating mandate on 24 September 2025. In the European Parliament, the draft report was presented on 18 November 2025 and a total of 49 amendments were tabled on 12 December 2025, focusing primarily on the definition and scope of small mid-cap enterprises (SMCs).

Implementing Acts

Not applicable.

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.

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 2025.
*Under discussion*

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 2025.
*Under discussion*

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

*Status Update*
On 10 December 2025, the Commission launched a public consultation on a draft Delegated Decision establishing exemptions from the reuse obligations for plastic wrappings and straps under the PPWR. The draft Delegated Act, based on Article 29(18)(a) of Regulation (EU) 2025/40, would exempt pallet wrappings and straps used for transport stabilisation from the 100% reuse obligations laid down in Article 29(2) and (3). Stakeholders may submit comments until 9 January 2026. Once adopted, the Delegated Act would apply from 1 January 2030, subject to scrutiny by the European Parliament and the Council.

Secondary legislation expected to be adopted throughout 2025.
*Under discussion*

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

Not applicable.

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*
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

Not applicable.

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*
Regulation (EU) 2025/2439 was published in the Official Journal of the EU on 3 December 2025. The measure will enter into force on 23 December 2025.

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.

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

Not applicable.

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*