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

*Status Update*
The proposal is currently under examination in the Council, with the latest exchange on a compromise text at COREPER II level, on June 26. In parallel, the European Parliament committees (ENVI, IMCO and TRAN) held an exchange on June 3. Amendments were issued via the simplified procedure without draft report in July.

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 presented on 10 December 2025 (COM(2025) 981 final) as part of the Environmental Simplification Package, amending Regulation (EU) 2023/1542 and Regulation (EU) 2024/1244 to reduce reporting requirements and administrative burdens.

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.
*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 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*
On 17 December 2025, the Commission adopted a package of eight implementing acts and one delegated act, which, now published in the Official Journal, thereby completing the legal framework for the definitive CBAM phase starting on 1 January 2026.

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.

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*
The proposal is currently under examination in the Council, with the latest exchange on a compromise text at COREPER II level, on June 26. In parallel, the European Parliament committees (ENVI, IMCO and TRAN) held an exchange on June 3. Amendments were issued via the simplified procedure without draft report in July.

*Status Update*
A political agreement on the trilogue negotiations was reached in mid-June 2026. The European Parliament and Council must now endorse the final draft before it can be submitted for publication in the OJEU.

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.
*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 published (Omnibus Package I).

Directive (EU) 2026/470, published in the Official Journal on February 26, 2026, amends Directive (EU) 2024/1760 by narrowing the scope of due diligence obligations.
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 March 18, 2026. Member States must transpose the CSDDD amendments by July 26, 2028.

*Status Update*
The European Commission issued a public consultation on June 12 on the guidelines for the implementation of the Directive. The consultation is open until July 24.

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 published (Omnibus Package I).

Directive (EU) 2026/470, published in the Official Journal on February 26, 2026, revises the scope of corporate sustainability reporting and due diligence obligations.
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 March 18, 2026. Member States must transpose the CSRD amendments by March 19, 2027.

Implementing Acts

The European Commission adopted on July 3, the Delegated Regulation for the revised European sustainability reporting standards (ESRS) and a voluntary reporting standard for smaller companies. The European Parliament and Council must endorse them in the coming two months.

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).

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 December 30, 2026, with a further six-month grace period for micro and small operators until June 30, 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.

Amendment

The European Commission issued on May 4, 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 products such as leather and retreaded tires. The European Commission is expected to adopt the delegated regulation soon, after which the European Parliament and Council must endorse without amendments. 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.

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*

A trilogue agreement was reached on June 9, 2026. The IMCO Committee is expected to endorse the trilogue agreement on July 14, 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

*Status Update*

The commission has submitted for public consultation a draft implementing regulation laying down the implementation arrangements for the digital product passport registry set up under the ESPR. The arrangements refer to areas of a technical nature and relate to the setup of the registry, and access management, as well as registered parameters. The European Commission will now review the comments before adopting the draft delegated act.

Key Obligations

Promote the enhancement of buildings’ energy performance, while also driving the reduction of greenhouse gas emissions from buildings.

Entry Into Force

*Status Update*
Member States had until May 29, 2026 to transpose the EPBD. According to the EU’s EUR Lex platform, five Member States have not notified any transposition measures, namely Denmark, Spain, Malta, Finland and Sweden. This opens the door for a potential action from the Commission against the Member States.

Postponement

Not applicable.

Amendment

Not applicable.

Implementing Acts

Delegated Regulation establishing a Union framework for the national calculation of the life-cycle Global Warming Potential (GWP) of buildings pursuant to Directive (EU) 2024/1275 (recast EPBD), replacing Annex III was issued in the Official Journal of the EU on May 4, 2026.

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*
The eight-week public consultation on the package has ended on May 7.

In the meantime, discussions on the file are progressing within the Council and the European Parliament. A group of Member States is 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. Strong resistances have also been expressed by MEPs. The EPP’s Rapporteur on the text is nonetheless willing to have a position adopted, should the Council revise its stance following the issuance of the Circular Economy Act. The vote of the ENVI Committee on the text has in any event been postponed from October 1 to November 4.

The Commission foresees an adoption of all initiatives in the package by the end of 2026.

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*
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.

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
*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*
A provisional trilogue agreement was reached on June 9, 2026. Subject to the technical requirements and formal adoptions, the file can be submitted for publication in the OJEU.

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

Commission Implementing Regulation (EU) 2026/903 on the authorities’ information and communication system was published on April 27, 2026.

*Status Update*
The European Commission issued its guidelines for the Forced Labor Regulation on 30 June 2026.

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.
*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 2026.
*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.

*Status Update*

On 30 March 2026, the Commission issued the PPWR Notice and FAQ.

Postponement

*Status Update*

Calls from the industry alongside certain Member States (i.e. the Czech Republic) are multiplying for the postponement of the August 12, 2026, application deadline. These have so far not been responded by the Commission.

Amendment

Not so far.

Implementing Acts

*Status Update*
On January 13, 2026, the Commission’s Joint Research Center (JRC) published a technical report on EU harmonized waste-sorting labels to support the preparation of the forthcoming implementing act establishing harmonized labeling specifications under the PPWR. The implementing act will follow the examination procedure and is expected to be adopted by August 12, 2026.

In addition, the JRC is expected to deliver a new report on other packaging labels (namely, labels for reusable packaging, deposit and return packaging, digital labels, recycled content and biobased content labels) in June 2026.

The delegated act exempting pallet wrappings and straps from the 100% reuse target for transport packaging under the PPWR has been published in the EU Official Journal on May 6, as Delegated Decision (EU) 2026/429.

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*
The Risk Assessment Committee (RAC) adopted its opinion on March 2. Shortly after, the Socio-Economic Assessment Committee (SEAC) adopted its draft opinion on March 10. Both were made available on March 26. The public consultation on the SEAC opinion ended on May 25.

The SEAC will work on the elaboration of its final opinion in the coming months. It will then be transmitted to the Commission alongside the RAC opinion. Both will contribute to the Commission’s decision-making in the elaboration of the draft restriction text.

In parallel, the Commission is weighing on how to address eight sectors not covered by the RAC and SEAC opinions due to a lack of information, namely printing; sealing; machinery; military applications; explosives; technical textiles; broader industrial uses (e.g., solvents and catalysts); and certain medical applications (e.g., immediate packaging). Several options are being considered, including the issuance of a new mandate for ECHA’s Committees to undertake a detailed assessment.

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*
Commissioner Roswall announced to Members of the European Parliament on April 27 that the Commission will not issue its REACH revision proposal. Instead, it will proceed to amend REACH annexes via comitology.

There is to date no timing defined for such revisions, although the press reports that the proposals are almost ready.

Implementing Acts

Not applicable.

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 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.