On 26 February 2026, the European Commission proposed an Omnibus package aimed at helping EU companies meet their sustainability obligations by simplifying certain sustainability reporting legislations. The vote on 3 April 2025 approved the proposal’s “stop-the-clock” mechanism, making headlines across Europe as businesses and stakeholders look to understand the implications and how to implement the changes. Stop-the-clock refers to an immediate change of deadlines regarding certain directives in the scope of the omnibus.
Despite the simplifications, the core objectives of these regulations remain unchanged. They continue to apply to non-EU firms as well, ensuring that external companies also meet the EU’s sustainability standards.
In this article, we will break down the main changes which have been proposed, as well as those which have already been approved, such as the “stop-the-clock” mechanism. We will take a look at what the changes – both proposed and those already adopted – mean for businesses, and the next steps your company can take to stay on top of the regulatory changes.
The Omnibus is a proposed regulation to simplify certain legislation within the EU in one package. The primary goal of this simplification is to enhance the competitiveness of EU companies, making it easier for them to comply with sustainability requirements and enabling them to better compete in global markets. This will help businesses make advancements in sustainability reporting by reducing administrative burdens.
The European Commission's Omnibus Simplification Package proposes updates and clarifications to key sustainability regulations, aiming to streamline requirements and ease administrative burdens. The following regulations are those impacted by the Omnibus changes:
The vote on the “stop-the-clock” mechanism has approved certain proposals, while others still remain to be voted on. Here is a list of the rules that have already been accepted, as well as those that are still awaiting a vote.:
On 3 April 2025, the European Parliament approved the installation of the "stop-the-clock" mechanism affecting both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D). This mechanism delays certain reporting deadlines under CSRD by two years for specific groups of companies.
The Omnibus stop-the-clock mechanism has been approved. However, the proposals regarding the changes to CSRD, CS3D, CBAM and Taxonomy have not yet been accepted. The European Parliament will not vote on these proposals until October 2025. Therefore, the original content of the legislation is applicable until then, meaning the scope and reporting requirements remain the same until the vote to change them has been approved.
As part of the ongoing negotiations surrounding the EU Omnibus package, a set of proposed changes has been introduced that could significantly impact large businesses operating within the European Union. While these proposals are still under discussion and have not yet been finalised or voted on, their potential scope and implementation may still evolve. Below is a summary of the key proposed revisions across various legislative instruments affected by the Omnibus.
Corporate Sustainability Reporting Directive (CSRD)The scope of the CSRD may be revised to apply only to companies with more than 1,000 employees, a shift that would exempt a broader swathe of smaller entities. Alongside this, the European Commission has proposed simplifications to the European Sustainability Reporting Standards (ESRS), including changes to sector-specific ESG disclosures. These measures aim to reduce administrative burden while maintaining the integrity of reporting. Additionally, the value chain reporting requirements would be reinforced through a strengthened “value-chain cap,” potentially placing more emphasis on traceability within supply chains.
Corporate Sustainability Due Diligence Directive (CSDDD)Proposals under the Omnibus package suggest narrowing the due diligence obligations to direct business partners only, thereby limiting the scope of liability unless a company has plausible knowledge of adverse impacts further down the value chain. The penalty framework would also be adjusted: rather than establishing EU-wide civil liability provisions, enforcement would be delegated to national frameworks, allowing for greater flexibility at the member state level.
EU Taxonomy RegulationTo ensure consistency with the revised CSRD thresholds, application of the EU Taxonomy could be limited to companies with more than 1,000 employees. A new opt-in mechanism is also being proposed, giving companies greater discretion over participation. Importantly, the number of mandatory reporting templates would be significantly reduced by approximately 70% in an effort to streamline compliance requirements and focus on material disclosures.
Carbon Border Adjustment Mechanism (CBAM)Several technical adjustments to CBAM are under consideration. These include the introduction of a new de minimis threshold: importers handling less than 50 tonnes of CBAM-covered goods per year would be exempt from obligations, a move likely to benefit SMEs and individuals. A simplified procedure is proposed for importers exceeding that threshold. Furthermore, the annual deadline for submitting CBAM declarations would shift from 31 May to 31 August, while the commencement of certificate sales would be delayed by one year from 1 January 2026 to 1 January 2027.
While the Omnibus proposes some adjustments, the core requirements of sustainability reporting legislation remain unchanged. Regardless of whether the changes are adopted, key obligations will still apply, and companies must integrate them into their operations. Here are some important rules of CSRD, CSDDD, Taxonomy and CBAM that remain unchanged:
There are still many regulations within the EU Greendeal that call for traceability and transparency throughout the value chain, which the Omnibus does not affect.
The ESPR aims to make products more sustainable by setting performance and information requirements across a product's lifecycle, including aspects like durability, reparability, and energy efficiency. It replaces the existing Ecodesign Directive, expanding its scope beyond energy-related products to include a broader range of goods.
One key element of the ESPR is the introduction of mandatory digital product passports (DPPs) for various categories of products. These passports will provide detailed, standardised information on a product’s environmental sustainability, enabling better consumer choices, more efficient recycling, and improved product tracking across the supply chain.
Companies will need to ensure their products comply with the new sustainability requirements, which may involve redesigning products, sourcing sustainable materials, and providing detailed product information to consumers.
Here are some of the key deadlines for the ESPR:
The EU Battery Regulation focuses on the entire lifecycle of batteries, promoting sustainability, safety, and circularity. It sets requirements for the sourcing, production, labelling, and recycling of batteries to reduce environmental impact.
Companies involved in the battery supply chain must ensure responsible sourcing of materials, meet recycling efficiency targets, and provide detailed information on the carbon footprint and recycled content of their batteries in a battery passport.
Here are some of the key deadlines for the Battery Regulation:
The CRMA aims to secure a sustainable and resilient supply of critical raw materials essential for the EU's green and digital transitions. It sets targets for domestic capacities in the extraction, processing, and recycling of these materials.
Here are some of the key deadlines for the CRMA:
The EUDR aims to prevent the import and sale of products linked to deforestation. It requires companies to conduct due diligence to ensure that commodities like cattle, cocoa, coffee, palm oil, rubber, soy, and wood, as well as derived products, are not associated with deforestation.
In order to comply, businesses must establish robust traceability systems, collect geolocation data of production areas, and ensure compliance with local laws to demonstrate that their products are deforestation-free.
Here are some of the key deadlines for the EUDR:
REACH is a comprehensive regulation governing the production and use of chemical substances in the EU. Having been in force in 2007 with reporting obligations since 2018, it requires companies to identify and manage risks associated with chemicals they manufacture and market in the EU.
Companies must ensure all substances they manufacture or import are registered with the European Chemicals Agency (ECHA). They must also communicate safety information down the supply chain and comply with any restrictions or authorisations applicable to their substances.
The EU Regulation on Prohibiting Products Made with Forced Labour on the Union Market, also known as the Forced Labour Regulation (FLR), entered into force in December 2024. This regulation prohibits the sale of products made with forced labour within the EU market, regardless of their origin. It empowers authorities to investigate and remove such products from the market.
Companies must conduct thorough due diligence to ensure their supply chains are free from forced labour. This involves assessing suppliers, implementing robust compliance systems, and being prepared for potential investigations by authorities.
Here are some of the key deadlines for the FLR:
The EU ETS is a cornerstone of the EU's policy to combat climate change, operating on a cap-and-trade principle to reduce greenhouse gas emissions cost-effectively.
Companies in energy-intensive sectors must monitor and report their emissions accurately, acquire sufficient allowances to cover their emissions, and explore opportunities to reduce emissions to lower compliance costs.
Here are some of the key deadlines for the ETS:
The End-of-Life Vehicles (ELV) Directive (Directive 2000/53/EC) aims to reduce the environmental impact of vehicles at the end of their life by promoting recycling, reuse, and recovery of materials, while limiting hazardous substances in vehicle components. Manufacturers are required to offer free take-back services for end-of-life vehicles, ensuring they are properly treated and recycled.
The directive sets targets for recycling and recovery, mandating that at least 85% of a vehicle’s weight be recycled, and 95% be recovered. Vehicles placed on the market after 2003 must also be free from hazardous substances such as lead, mercury, cadmium, and hexavalent chromium, with limited exemptions.
These ongoing obligations focus on designing vehicles for easier recyclability, and manufacturers must report the percentage of recycled materials used in new vehicles.
The European Union's Classification, Labelling, and Packaging (CLP) Regulation (EC No 1272/2008) aligns the EU system with the United Nations' Globally Harmonised System (GHS) to ensure a high level of protection for human health and the environment. This regulation standardises the classification and labelling of chemicals, facilitating their safe use and free movement within the EU market.
Companies involved in manufacturing, importing, or distributing chemicals within the EU must comply with the CLP Regulation by classifying, labelling, and packaging substances and mixtures according to its criteria. This includes updating labels to reflect new hazard classifications, ensuring online platforms clearly display hazardous properties, and adhering to specific labelling requirements for various packaging formats.
Businesses should also monitor and implement changes introduced by adaptations to technical progress (ATP), such as the 21st ATP, which requires compliance by September 2025.
Despite updates proposed in the Omnibus Package, businesses must still meet existing sustainability obligations. The extended timeline is a chance to strengthen, not postpone, compliance strategies. Inaction risks non-compliance, with potential penalties including fines or loss of EU funding and investment opportunities.
Businesses must therefore remain focused on complying with other essential regulations like the Ecodesign for Sustainable Products Regulation (ESPR), ensuring that their products meet sustainability requirements. Staying compliant with these regulations is crucial to avoid financial penalties and reputational damage.
Sustainability is a powerful long-term strategy that can create significant value and resilience for businesses. Maintaining transparency in ESG reporting is vital, as it helps meet stakeholder expectations, builds trust, and sustains a competitive edge in the evolving marketplace. By keeping a close eye on legislative developments and proactively adapting to regulatory changes, businesses can stay ahead of the curve and ensure they’re always prepared for new requirements and deadlines.
The EU Taxonomy Regulation is a key component of the European Union’s Green Deal, designed to guide investors, businesses, and policymakers in identifying environmentally sustainable economic activities. By setting clear criteria for what qualifies as sustainable, the Taxonomy aims to regulate greenwashing, ensure transparency in financial markets, and attract capital towards truly sustainable investments.
As part of the EU’s broader sustainable finance agenda, the Taxonomy complements initiatives such as the Ecodesign for Sustainable Products Regulation (ESPR) and the Corporate Sustainability Reporting Directive (CSRD). Together, these policies aim to realign the financial system with the EU’s climate and environmental goals, reinforcing the commitment to climate neutrality by 2050.
In this article, we will break down the main features of the EU Taxonomy regulation and discuss its potential modifications in light of the new EU Omnibus Regulation proposal.
The EU Taxonomy is essentially a classification system that defines whether an economic activity is environmentally sustainable based on six key environmental objectives:
For an activity to qualify as aligned with the EU Taxonomy, it must substantially contribute to at least one of these objectives without significantly harming any of the others. The regulation also establishes minimum social safeguards, ensuring compliance with human rights and labour standards.
By defining clear sustainability standards, the EU Taxonomy ensures that financial and corporate activities genuinely contribute to the green transition. This classification system provides investors, businesses, and policymakers with a credible, science-based tool to evaluate environmental impact, reduce greenwashing, and direct capital toward truly sustainable initiatives.
The EU Taxonomy has garnered significant attention recently, as it is one of the legislations included in the EU Omnibus proposal. The proposal seeks to simplify the means of EU corporate sustainability reporting.
The main changes proposed regarding the EU Taxonomy concern its obligatory nature and the extent of the reports. Firstly, the proposal aims to make the regulation a voluntary scheme. If passed, it would mean that companies can choose to opt in on reporting on their sustainable economic activity. The actual reports themselves are aimed to be simplified, although the specifics have not yet been released.
The EU Taxonomy Regulation applies to a wide range of entities, particularly those involved in finance, corporate reporting, and investment decision-making. Until the changes proposed by the EU Omnibus are approved and officially adopted into domestic legislation, the following scope remains applicable.
The main groups impacted include the following:
By targeting these key actors, the EU Taxonomy aims to redirect capital towards environmentally sustainable activities, thereby helping to drive the transition to a climate-neutral economy by 2050.
For an economic activity to be classified as environmentally sustainable under the Taxonomy, it must meet three core criteria:
As mentioned above, EU Taxonomy consists of objectives to make business operations within the EU more sustainable, efficient and aligned with the goals of the EU Green Deal and the Circular Economy Action Plan.
Here are practical examples of how businesses can implement the Taxonomy objectives into their operations to be compliant with the regulation:
While implementation of as many as possible is encouraged, following merely one of these principles is sufficient, as long as other business activities do not significantly harm the other principles.
The EU Taxonomy Regulation was adopted in July 2020, and its implementation has been rolled out in phases. The first set of Taxonomy Technical Screening Criteria was introduced in December 2020, covering climate change mitigation and climate change adaptation objectives.
From January 2022, financial market participants and large companies, particularly those covered by the Non-Financial Reporting Directive (NFRD), were required to begin reporting on how their investments align with the Taxonomy, focusing on climate-related objectives.
By January 2023, companies were expected to expand their disclosures to include additional objectives like water protection, circular economy, and biodiversity. As the Taxonomy evolves, more economic activities will be included, particularly those supporting the green transition. Further refinements are anticipated with the EU Omnibus Regulation proposal.
Implementing the EU Taxonomy Regulation presents several challenges for companies, particularly in terms of data collection and reporting. The need to gather accurate, standardised data across the global value chain operations can be resource-intensive, especially for smaller enterprises lacking the necessary infrastructure. Moreover, this can further lead to supplier fatigue and confusion due to the lack of clear guidelines and data collection methods, which can in turn lead to increased costs and administrative errors.
The administrative burden associated with compliance is another significant concern. Companies are required to provide extensive proof of compliance, which can be particularly challenging for smaller suppliers who may lack the resources to adapt to changing standards and technologies. This situation has led to calls from various stakeholders for simplification of the regulatory framework to alleviate these burdens.
The Omnibus proposal aims to revise key elements of the EU Taxonomy, most notably by making it a voluntary rather than mandatory regulatory framework. This change would mean companies only need to report if they choose to opt in, and even then, the reporting requirements would be simplified, although the extent of that simplification has yet to be defined.
Even if the EU Taxonomy reporting becomes voluntary due to the EU Omnibus proposal, many companies may still find strategic value in opting in. Here are several compelling reasons why:
To navigate the challenges of data collection, reporting, and supplier fatigue from the diverse regulations companies are subject to, companies can adopt digital solutions that enhance efficiency, transparency, and compliance. Digital product passport (DPP) store key environmental and lifecycle data, automating data capture and standardising reporting to ease administrative burdens and improve supply chain insight.
At the same time, Circularise’s blockchain-based traceability platform offers a secure way to track sustainability metrics while safeguarding sensitive business data. Already used in sectors like plastics, chemicals, and batteries, these tools empower companies to meet regulatory demands and advance their sustainability goals. As regulatory demands continue to evolve, leveraging these technologies will be essential for maintaining compliance, improving supply chain collaboration, and driving sustainable investment.
The EU Taxonomy Regulation is a strategic framework designed to direct capital and corporate action toward a truly sustainable economy. By offering a science-based, transparent system to define what counts as environmentally sustainable, the Taxonomy curbs greenwashing, builds investor trust, and helps align private sector efforts with the EU’s climate neutrality goals for 2050.
Though the proposed EU Omnibus Regulation may ease reporting obligations by making them voluntary and streamlining disclosures, this should not be mistaken for a signal to step back. On the contrary, companies that proactively engage with the Taxonomy stand to gain: they strengthen credibility with stakeholders, sharpen ESG capabilities, and position themselves ahead of future regulatory shifts.
Moreover, in an increasingly competitive and sustainability-driven market, early adopters of the Taxonomy can distinguish themselves as leaders in environmental responsibility and innovation. Transparent reporting demonstrates a proactive stance on climate action and responsible governance, traits that are becoming increasingly essential for securing long-term stakeholder trust and access to capital.
Ultimately, engaging with the EU Taxonomy, even on a voluntary basis, offers companies a powerful opportunity to drive environmental impact, improve operational resilience, and contribute to the broader green transition. As sustainable finance becomes the norm, aligning with the EU Taxonomy today is an investment in the business and regulatory landscape of tomorrow.
The fourth industrial revolution has been fueled by an explosion of information. From social media to home appliances, everything produces data. This includes details about our health, location, preferences, and behaviours. The amount of data we create is expected to grow exponentially, and around 150 years from now, digital bits will exceed atoms on Earth. In 2020 alone, 79 trillion gigabytes of data were generated — but where does all the data go, who owns it and has the right to use it, and what is the best way to share it?
This article sets out to summarise the main data debates and the European Union’s (EU) regulations that arise from them. In particular, you will learn about the complex landscape of data governance in the EU, including the advantages and challenges of big data, privacy concerns, and key regulations like GDPR and the Data Act.
We will also explore the development of common data spaces across various sectors, such as the European Single Access Point for finance, manufacturing data spaces, and the European Dataspace for Smart Circular Applications, which aim to foster innovation, sustainability, and economic growth while maintaining data sovereignty and protection.
Consumer data can be used for various purposes, and while some data applications are promising, others are potentially harmful. Diverse aggregated data delivers richer insights and helps in meeting the needs of new products and services. For example, the use of data has the potential to allocate resources better to fight malaria, consequently saving up to 5 billion euros. Furthermore, harmonised data collection can enable large-scale collaboration, hence accelerating innovations in such fields as AI and circular economy. Data pooling also creates an opportunity to increase transparency and data sovereignty by keeping companies and individuals who generated it in control and empowering those stakeholders affected by data processing to access it. Data sovereignty is the principle that digital information is subject to the laws of the country where it is generated, even if stored or processed elsewhere under data residency or localisation rules.
At the same time, risks to privacy and security arise when personal data is handled inappropriately. Security breaches or loss of data are almost inevitable, while privacy protection is costly and time-consuming — unless effective legal and technological measures are put in place.
Sometimes, the benefits of data are not accessible to all, creating knowledge and power asymmetry between firms who own the data and individuals who do not. Instagram and Facebook can see what people like and share, Google what we search for, and Amazon what we buy. Big corporate players start accumulating capital by collecting and selling this behavioural and other data as a market commodity. When Google began using personal data for advertisement, it managed to increase its revenues by a shocking 3590%7. Similarly, Facebook’s 2019 revenue accounted for 20% of the $333 billion worldwide digital advertising market. Even as businesses capture the growing potential of the data economy, many data subjects pay little attention to what happens to their information.
There are two potential explanations as to why the majority of the users are careless with their data, even when such an attitude is unfavourable. First, it might lie in the fact that consumers are not yet accustomed to seeing data as a unit of exchange, thinking in conventional monetary terms. Unless it is money, it is not valuable, or not valuable enough. Another explanation might be that data subjects do not see data as something that can be owned.
Some people stress the need to not only start treating data as a tradable property that can be owned, but also as a fundamental right to privacy4. However, by doing so, they forget that privacy and data protection are already human rights in many jurisdictions. For example, Article 8 of the EU Charter of Fundamental Rights - which was created in 2000 - states:
"Everyone has the right to the protection of personal data concerning him or her. Such data must be processed fairly for specified purposes and on the basis of the consent of the person concerned or some other legitimate basis laid down by law. Everyone has the right of access to data which has been collected concerning him or her, and the right to have it rectified."
In those regions where data regulations are already in place, the problem then lies within the weak legal regimes that do not develop fast enough and cannot account for nascent threats. To utilise the benefits of data proliferation without suffering the risk associated with it, successful data management has to enhance the flow of information in the economy while simultaneously effectively protecting it. The issue calls for tighter and more detailed technological regulations, which policymakers in the European Union (EU) have started to respond to.
At the centre stage of these efforts to ensure the effectiveness of regulation is the EU, with its dynamic and innovative data economy that is estimated to grow to 829 billion euros by 20253. In February 2020, the European Commission published the European data strategy. The framework sets a general direction for data regulations. The strategy increases the availability of data for better EU-wide decision-making, while keeping those who generated it in control.
The priorities are:
The strategy for data is not only limited to guaranteeing privacy but also focused on ensuring secure management of the data economy as public infrastructure, which includes handling (collection, storage, and distribution) of data. The key data management initiatives are the General Data Protection Regulation (GDPR), Data Act, and European data spaces (the European Single Access Point, data spaces for smart manufacturing, and the European Dataspace for Smart Circular Applications).
In May 2018, the EU rolled out the General Data Protection Regulation (GDPR). The GDPR is believed to be one of the most rigid privacy and security regulations in the world9. It establishes a harmonised framework for the protection of personal data by setting requirements for collecting, storing, and managing it.
The regulation mainly applies to:
The GDPR describes 6 conditions under which firms have a right to collect personal data, such as the presence of a formal opt-in of a data subject. In all of these cases, firms are required to be transparent about how the data is managed13. The GDPR is a complex and elaborate law, but the minimum information to be included is:
Another focus area of the regulation is users’ empowerment. The increased transparency around what happens to the data gives the subjects the right – after it has been collected – to access, rectify, erase, and transfer the data, as well as to lodge a complaint about data usage12.
Within organisations that regularly process large scales of users’ data as a core business activity, compliance with these requirements has to be monitored by a data protection officer designated by the company. The officer serves as a contact point for data subjects and the Data Protection Authority. The officer is also responsible for keeping a record of company acts. Firms that violate the EU’s privacy rules risk fines up to either 4% of their annual turnover or 20 million euros. Furthermore, additional measures such as an order requesting to stop data handling might be considered.
The European Data Act is the first deliverable of the European data strategy. The proposal was published on 23rd February 2022 and entered into force in January 2024. The European Data Act aims to make valuable data more accessible between companies and consumers in all economic sectors. It harmonises rules on fair access to and use of data, cloud switching, and transfers by setting relevant obligations for stakeholders.
Such obligations are of a contractual, commercial, and technical nature and specify who, other than manufacturers or other data holders, is entitled to access the data generated by products, under which conditions and on what basis. Examples of the requirements are designing products in a way that makes the data they collect easily accessible by default, ensuring a secure transfer of data to other providers, or pushing providers to prevent unlawful third-party access to non-personal data held in the EU.
The stakeholders affected by the regulation are companies handling data, providers of Internet of Things (IoT) products, and cloud service providers. Fines will be imposed on those non-compliant with the requirements.
As regulations, the GDPR and the European Data Act set rules governing obligations for organisations handling data to protect consumer data and encourage information sharing. However, to fulfil some of its obligations, the policies need to be complemented by a relevant digital infrastructure. For example, to ensure a secure transfer of data to other providers, a system that can read data in a single format must be established to make a successful data transfer. This is in part fulfilled by the introduction of industry-specific common European data spaces.
The European strategy for data includes an objective to create common and interoperable data spaces3. Data spaces connect governance frameworks (e.g. the GDPR and the European Data Act) and relevant digital infrastructure (tools and services) for secure and scalable data merging, processing, and sharing across the EU. Data stored in the European data spaces includes information that is required to be publicly disclosed under EU legislation – such as the CSRD, GDPR, or ESPR – as well as voluntarily shared data.
The European data spaces are currently being created in 14 fields of economic and public interests, with an intention to gradually enlarge to other sectors:
One of the data spaces currently being developed for the financial sector is the European Single Access Point (ESAP). The European Single Access Point offers an ability to examine public financial and sustainability-related information that firms operating in the EU have to share in accordance with the standards for reporting, such as the Sustainable Finance Disclosure Regulation, the EU Taxonomy, and the Corporate Sustainability Reporting Directive (CSRD). The measure aims to ensure that key stakeholders such as investors, banks, customers, and consumers can easily access the required information about entities and products.
The proposal text describes a set of technical principles to be followed when collecting the information:
The initiative is scheduled to be operational by summer 2027. From this date, management reports, annual financial statements, sustainability statements, and audit reports will be made available via ESAP.
In the industrial sector, the data spaces for smart manufacturing aim to enable key actors in the supply chain (e.g. supplier, client, service provider), including those firms involved with the circular economy (e.g. remanufacturing and recycling companies), to access large amounts of manufacturing data. Thus, addressing the industrial data silos and high fragmentation of the supply chain digitalisation.
The dataspaces are now being created for specific value chains through several workshops with stakeholders. Some questions under discussion are:
In November 2021, the Commission published a call for proposals to establish two viable manufacturing data spaces. The work started around July-September 2022 and will last 1-2 years.
Similarly, there is a plan to create several data spaces for information necessary for reaching the objectives of the European Green Deal20. One of these data spaces is the European Dataspace for Smart Circular Applications (EDSCA), which is a registry that makes available the relevant data for enabling circular value creation along supply chains. This data is related to such applications and services as:
The call for proposals for working on the data space was published in 2021 and the project started around July-September 2022 and lasted two years. The EDSCA first assisted in the creation of DPPs for electronics and batteries, and then expanded to textiles and building materials.
Read more about the DPPs and the requirements for the battery passports.
The European Commission sees several key advantages in setting up data spaces16.
Ultimately, the European Commission believes the standards will provide a coordinated technical infrastructure prioritising the findable, accessible, interoperable and reusable principles. It is essential to bear in mind, however, that whether all these aspirations become a reality depends greatly on the implementation of the strategy, as well as its effectiveness in addressing key challenges associated with data processing mentioned at the beginning of the blog post.
Big data offers both significant opportunities and potential risks. To harness its benefits while minimising harm, a robust governance system with strict, harmonised rules for data handling is essential — an approach the EU has already begun to implement. The European data strategy sets a general direction for data regulation, prioritising the single market for data and data economy.
Following the strategy, the General Data Protection Regulation sets out to protect users’ personal data. The European Data Act establishes the harmonised rules to encourage information sharing by service providers and firms handling data. The regulations require the establishment of industry-specific common European data spaces (e.g. the European Single Access Point (ESAP) for the financial sector, European Dataspace for Smart Circular Applications (EDSCA) for reaching the objectives of the Green Deal, and two other dataspaces for smart manufacturing that are yet to be defined). These spaces connect the aforementioned governance frameworks with relevant digital infrastructure for secure and scalable data merging, processing, and sharing.
Besides the GDPR that came into effect in 2018, other policy measures are still in development. The European Data Act was published in December 2023 and will become applicable on 12 September 2025. The least progress has been made with data spaces. Among them, the most defined are the data spaces in the financial sector. The main challenge in policy formulation for other sectors seems to lie in defining what data to share and through which medium (e.g. centralised versus decentralised storage).
To be ready for the new requirements for data spaces, firms need to start preparing now. For example, the regulations around the ESAP and EDSCA require the data to be included in DPPs or annual management reports to be disclosed in a machine-readable format. Hence, organisations should already start thinking about how to implement a new secure and scalable enterprise system for storing and sharing data that is to be made public.
Stakeholders should closely monitor the policy progress because the European data strategy, being the first fully fledged data management framework, will define how the narrative around big data (should data be owned, be seen as a unit of exchange or perceived as a fundamental right, and other) will evolve and, most importantly, will test how to implement in practice.
Want to know more about other regulations mentioned in this article? Read our blog post explaining the digital product passports (DPPs), battery passports, CSRD, and ESPR.
Circularise provides an end-to-end traceability solution for complex supply chains. We help companies verify the origins, certificates, CO2 footprint, and other material and product data on the blockchain to improve their ESG performance, demonstrate responsible sourcing, and enable a circular economy at scale.
Every year, a total of 15 billion trees are cut down, contributing to the loss of 10 million hectares of forest annually – an area about the size of Scotland and Wales combined.1 This not only devastates ecosystems and accelerates biodiversity loss but also poses significant challenges to global supply chains and businesses worldwide.
In response, the EU Deforestation Regulation (EUDR) aims to promote the use of “deforestation-free” products and reduce the EU's contribution to global deforestation.2 It applies to both products produced within the EU and potentially exported, as well as products imported into the EU market. EUDR covers key goods like cattle, cocoa, coffee, palm oil, rubber, soy, and wood, along with their by-products.
Under the EUDR, companies have to ensure their products originate from land where no deforestation or forest degradation has occurred since 31 December 2020 and comply with relevant laws in the country of production. In order to comply, businesses must go beyond basic compliance and leverage innovative digital traceability solutions.
This article will explore the nuances of the EUDR, its purpose, implementation timeline, the businesses and products affected, and the data requirements for compliance. It will also examine how technologies like blockchain and digital product passports can simplify and enhance EUDR due diligence processes.
As global warming becomes an increasing concern worldwide, one of the main responses from the EU is the Green Deal. The Green Deal policy aims to make the EU the world’s first climate-neutral continent by 2050. Its focus lies in reducing greenhouse gas emissions, promoting sustainable practices, and transforming various sectors such as energy, agriculture, and industry.3
The EUDR is a key component of the broader Green Deal, complementing other targeted policies to address the most critical sectors. Together, these measures drive progress toward the ultimate goal of climate neutrality by 2050. EUDR replaced the EU Timber Regulation (EUTR), which was primarily focused on fighting illegal logging4, while the EUDR expanded its scope to include a wider range of activities that are linked to deforestation.
This change in scope acknowledges that a large portion of deforestation is actually legal. Therefore, the EUDR aims to combat both legal and illegal deforestation. Aligning EUDR with the Green Deal highlights the EU’s commitment to reducing its impact on global forests and combating climate change, reflecting a comprehensive approach to address environmental concerns and promote sustainable supply chains.
The main objective of the EU Deforestation Regulation (EUDR) is to address global deforestation and promote sustainable supply chains by5:
The policy aims to fight global deforestation and promote sustainable supply chains through several core objectives:
These objectives collectively work to protect forests, reduce carbon emissions, and foster responsible business practices worldwide, widening the impact far beyond EU borders. However, this has implications for businesses, mainly increased due diligence obligations and restrictions to market access.
The EUDR’s revised implementation dates are set for 30 December 2025 for large businesses and 30 June 2026 for micro and small enterprises.6 This delay was given to grant third countries, member states, operators, and traders more time to prepare for the extensive due diligence obligations required due to concerns of not being able to comply in time.
Despite the postponement of a year, businesses must still prepare for the regulation's complex and wide-ranging requirements. EUDR demands rigorous supply chain monitoring and geolocation data collection, down to the level of "plots of land".7 Therefore, mapping your supply chain to implement an end-to-end traceability solution is essential for compliance.
The scope of industries affected by the EU Deforestation Regulation (EUDR) includes agriculture, timber, soy, palm oil, cocoa, and rubber. In all cases, the responsibility to comply falls on the business placing the product on the EU market, not on the producer.8 Companies in these sectors must ensure their products are deforestation-free, traceable to their source, and compliant with local laws.
For the palm oil industry, this regulation affects producers of food, cosmetics, and cleaning products, requiring detailed geolocation data and documentation to prove sustainable sourcing. Similarly, the rubber industry faces strict requirements for products like tyres and inner tubes, which fall under EUDR’s scope. Businesses must implement robust traceability systems, conduct supply chain audits, and mitigate risks of deforestation.
The regulation especially impacts supply chains and market competitiveness, potentially shifting trade patterns and restricting market access for non-compliant products. While this can lead to increased operational costs, it can also create competitive business advantages for early adopters of sustainable practices as more businesses seek out EUDR-compliant suppliers.
Businesses must collect, organise, and retain the following information for five years from the date of placing relevant products on the market or exporting them:
The regulation highlights a three-tier system which will be used to assess countries or specific regions within them. Member States and third countries, or their subdivisions, will be categorised into one of the following risk levels9:
Companies sourcing from high-risk areas face stricter due diligence requirements, increased compliance costs, and potential market access challenges. Those sourcing from low-risk regions may benefit from simplified procedures and easier market entry. This system will likely influence supply chain management strategies, with companies potentially shifting away from high-risk sources. It also requires enhanced supply chain traceability and transparency, especially for high-risk products.
This risk-based approach could influence how businesses adjust their operations and risk mitigation strategies as businesses navigate compliance with the EU’s zero-deforestation goals. At the same time, companies must balance these adjustments with managing compliance costs and maintaining market access.
EUDR presents both significant challenges and opportunities for businesses. Businesses face implementation difficulties due to limited guidance from the EU Commission and concerns about the reliability of the proposed IT system for registering due diligence information.10 There's also a risk of smallholder exclusion as larger companies may opt to simplify their supply chains for compliance. Legal and trade-related issues arise from potential conflicts between geolocation data sharing and national regulations, with some countries viewing EUDR as a technical trade barrier. The increased administrative burden and compliance costs pose additional challenges.11
To address these issues, businesses are adopting various solutions and preparation strategies:
Collaboration has emerged as a vital strategy, with companies engaging industry associations, NGOs, and government bodies to share best practices and collectively address challenges. Various consultancy firms, technology providers, and certification bodies are also developing solutions to assist businesses in complying with EUDR requirements. As the regulation's implementation date approaches, these preparatory actions are becoming increasingly critical for affected industries. Companies need to implement effective traceability systems that ensure the origins of their raw materials are well-documented. This is where understanding the different chain of custody models becomes essential for managing risk and proving compliance.
Under the EUDR, the primary responsibility for compliance lies with economic operators and traders active in the EU market for relevant commodities and products12.
Non-compliance is heavily penalised, including fines of up to 4% of EU annual turnover, temporary bans from public contracts and funding, and potential confiscation of non-compliant goods13. Under EU law, greenwashing could also lead to severe consequences for companies that inadvertently mislead consumers about the environmental impact of their products or services. Regulatory crackdowns, hefty fines, and reputational damage are all risks businesses face if their sustainability claims are not backed by verifiable data.
Beyond mere compliance, EUDR preparation offers long-term benefits in traceability, sustainability, and risk mitigation. Despite the implementation deadline being extended to 30 December 2025, businesses should not delay their preparations. Early compliance efforts can also help align with other sustainability regulations, such as the Ecodesign for Sustainable Products (ESPR), as well as the US Inflation Reduction Act (IRA).
Early adopters of digital compliance tools can gain a significant competitive advantage by demonstrating a commitment to sustainability. This not only strengthens brand reputation but also enhances market positioning.14 Businesses should proactively explore digital traceability solutions that help ensure regulatory compliance and drive operational efficiency and sustainability.
Circularise offers a leading platform for end-to-end traceability, providing solutions like digital product passports to streamline data collection and sharing while safeguarding sensitive information.
This is Part 7 of the series "Get Ready for ESPR: Shaping the Future of Sustainable Business."
The Ecodesign for Sustainable Products Regulation (ESPR) is going to be transformative, but it comes with its fair share of challenges. Businesses must navigate overlapping reporting requirements, tight deadlines, and the need to modernise outdated systems — all while ensuring that suppliers and stakeholders stay engaged. This article will explore these challenges in detail and provide actionable strategies to help your organisation.
The ESPR does not operate in isolation. Businesses must also comply with other reporting frameworks, such as the Corporate Sustainability Due Diligence Directive (CS3D) and the Corporate Sustainability Reporting Directive (CSRD). The overlap between these frameworks can create confusion and increase the administrative burden. You can address this by:
The ESPR introduces staggered compliance deadlines, with some requirements starting as early as 2025. For businesses operating across global supply chains, these deadlines can feel unmanageable, especially for those who have yet to start preparing. Get started by:
Suppliers are facing increasing demands to provide data, implement new processes, and meet various compliance standards. "Supplier fatigue" can lead to delays or lapses in cooperation, hindering your compliance efforts. For companies operating across multiple regions, aligning supply chain operations with ESPR can be challenging, particularly when working with non-EU suppliers unfamiliar with the regulation. Address this challenge by:
Traditional systems, such as email chains or siloed databases, are no longer sufficient for managing the complex data-sharing and traceability requirements of ESPR. In order to not rely on outdated systems and risk falling behind in your compliance efforts, you can:
Achieving ESPR compliance requires input from multiple departments, including design, legal, procurement, and marketing. Misalignment between these teams can lead to delays and inefficiencies. Therefore, it is important to:
Meeting ESPR requirements often involves significant upfront investment in technology, staff training, and operational changes. Here are some ways to manage this challenge:
While the path to sustainability has its challenges, each obstacle presents an opportunity to strengthen your organisation’s sustainability practices. By addressing overlapping reporting frameworks, engaging suppliers, modernising systems, and fostering internal alignment, businesses can not only meet regulatory requirements but also position themselves as leaders in the transition to a circular economy.
This concludes our ESPR 7-part series and email course designed to help you navigate the challenges and opportunities of the Ecodesign for Sustainable Products Regulation (ESPR). We hope these lessons have provided valuable insights into compliance strategies, sustainability practices, and the tools you need to succeed in a circular economy.
📚 Explore the series at your own pace.
Part 1: What you need to know about ESPR
Part 2: Horizontal rules under ESPR
Part 3: Sustainable discarding and destruction of products under ESPR
Part 4: ESPR enhances traceability and transparency with digital product passports
Part 5: Specific ESPR requirements for manufacturers, importers, distributors, and retailers
Part 6: Why stakeholder collaboration matters for ESPR compliance
This is Part 6 of the series "Get Ready for ESPR: Shaping the Future of Sustainable Business."
This article will explore how different teams within your company can collaborate to not only comply with the Ecodesign for Sustainable Products Regulation (ESPR) but also maximise your competitive advantage.
Complying with the ESPR is not a task for one department — it’s a cross-functional effort. From ensuring sustainable product design to managing supply chain traceability and aligning financial strategies, every team must play a role in embedding sustainability into the business. By understanding these roles, organisations can ensure seamless compliance while unlocking benefits such as cost savings, enhanced customer trust, and competitive market positioning.
Design and engineering teams are at the forefront of ESPR compliance. They must create products that meet the regulation’s strict sustainability requirements while balancing performance and cost.
Key responsibilities:
💡 Example: Stress test components to identify potential weak points and ensure compliance with ESPR durability standards.
Supply chain teams play a crucial role in ensuring traceability and ethical sourcing, both key aspects of ESPR compliance.
Key Responsibilities:
💡 Example: Use batch-level or item-level DPPs to track material flows and share sustainability data with partners.
Operations teams must adapt production lines and processes to meet ESPR requirements while maintaining efficiency and safety.
Key responsibilities:
💡 Example: Adapt production lines to incorporate recycled materials and reduce energy consumption.
The finance and legal teams ensure compliance with ESPR’s regulatory framework while mitigating financial risks associated with non-compliance.
Key responsibilities:
💡 Example: Develop a compliance budget that includes investments in IT infrastructure for managing DPPs.
Sales and marketing teams must communicate the sustainability benefits of ESPR-compliant products while ensuring transparency with customers.
Key responsibilities:
💡 Example: Add direct links to DPPs on product pages and train sales teams to explain sustainability features effectively.
ESPR compliance requires a shared commitment across all departments. Each stakeholder must understand their role and collaborate to ensure the company meets the regulation’s sustainability and circularity goals. By embedding compliance into daily operations, organisations can not only avoid penalties but also position themselves as leaders in sustainable business practices.
In Part 7, the final article, we’ll address how to tackle challenges in ESPR compliance and refine strategies for continuous improvement.
📚 Explore the series at your own pace.
Part 1: What you need to know about ESPR
Part 2: Horizontal rules under ESPR
Part 3: Sustainable discarding and destruction of products under ESPR
Part 4: ESPR enhances traceability and transparency with digital product passports
Part 5: Specific ESPR requirements for manufacturers, importers, distributors, and retailers
Part 7: Turning compliance challenges into opportunities with ESPR
This is Part 5 of the series "Get Ready for ESPR: Shaping the Future of Sustainable Business."
The Ecodesign for Sustainable Products Regulation (ESPR) imposes several compliance obligations on various players across the product value chain, from manufacturers to retailers. Here, we will cover the key responsibilities of manufacturers, importers, distributors, and retailers in ensuring their products meet the sustainability and design criteria outlined by the ESPR. Understanding these obligations is crucial for not only complying with EU regulations but also positioning your business for greater sustainability and transparency.
Manufacturers play a critical role in the ESPR by ensuring that products meet sustainability standards from the start of the design phase. This section outlines the key responsibilities of manufacturers to ensure products are ESPR-compliant.
Importers are responsible for ensuring that products from outside the EU comply with ESPR regulations before entering the market. This section covers the specific obligations importers need to follow.
Distributors are responsible for ensuring that products meet ESPR standards when they reach retailers and consumers. Distributors must verify that all required documentation is in place, halt sales of non-compliant products, and assist in corrective actions. Here’s an outline of the essential obligations distributors must follow.
Retailers play an important role in ensuring that customers are informed about the sustainability of the products they purchase. Retailers must the DPP easily accessible and ensure compliance with labelling and transparency requirements. Below are the key obligations retailers need to follow under ESPR.
In this article, we covered the core ESPR obligations for manufacturers, importers, distributors, and retailers, including product design, documentation, labelling, and corrective actions. These steps are essential for compliance and promoting sustainability throughout the product lifecycle. We prepared this in a handy table. If you wish to get it delivered to your inbox, sign up for our ESPR course below.
In Part 6, we’ll explore the roles of different stakeholders within a company and what they can do to ensure ESPR compliance across the organisation.
📚 Explore the series at your own pace.
Part 1: What you need to know about ESPR
Part 2: Horizontal rules under ESPR
Part 3: Sustainable discarding and destruction of products under ESPR
Part 4: ESPR enhances traceability and transparency with digital product passports
Part 6: Why stakeholder collaboration matters for ESPR compliance
Part 7: Turning compliance challenges into opportunities with ESPR
This is Part 4 of a the series "Get Ready for ESPR: Shaping the Future of Sustainable Business."
A digital product passport (DPP) is an effective traceability system that collects and shares critical data about a product throughout its lifecycle, from production to disposal. This information is designed to help businesses, consumers, and other stakeholders understand the environmental impact of products, as well as their materials, performance, and recycling potential.
Under the Ecodesign for Sustainable Products Regulation (ESPR), DPPs are mandatory for many product categories, and their role is essential in driving the EU's transition to a circular economy.
Digital product passports are mandatory for a wide range of products regulated under the Ecodesign for Sustainable Products Regulation (ESPR). These include the following:
Manufacturers, importers, distributors, and retailers of these products must ensure their DPPs are accessible by 19 April 2025. The European Commission will update the list of products subject to DPP requirements as the ESPR evolves.
The ESPR outlines several key data points that must be included in a DPP to ensure transparency and traceability across the product lifecycle. These data requirements help stakeholders better understand the environmental and sustainability impacts of products.
Here are the critical elements of a DPP:
Each product must be uniquely identifiable to ensure traceability throughout its lifecycle. This includes:
Details regarding the performance and sustainability of the product, including:
Products must provide detailed information about substances that could be harmful to human health or the environment:
This section provides information that extends the product's useful life and ensures safe disposal:
DPPs should include information that supports sustainability efforts and reduces environmental impact:
Details that enable product repair, replacement, and modularity:
Information that helps ensure materials stay in use within the circular economy:
Implementing a DPP system requires a robust data infrastructure and cooperation across the supply chain. While the process can seem daunting, the right tools and technology make it manageable:
Start by identifying the key information that should be included in the DPP for your products. This may include product specifications, sustainability data, and lifecycle tracking.
Work with stakeholders across the supply chain to define the data-sharing process and ensure that all parties have access to the necessary information.
Use technologies such as barcodes, QR codes, RFID tags, and blockchain to store and transfer DPP data. This makes it easier to implement and ensures that the data remains secure and accessible.
Ensure that proprietary information is protected, and use encryption or decentralised systems to maintain the integrity and privacy of the data.
Regularly update the DPP to reflect changes in the product, including modifications to materials, performance, or end-of-life management.
Digital product passports are a powerful tool for businesses to improve product transparency, enhance sustainability efforts, and comply with the Ecodesign for Sustainable Products Regulation (ESPR). By providing detailed, accessible data about a product’s lifecycle, DPPs enable stakeholders to make more informed decisions, drive circular business models, and meet growing consumer demand for sustainability.
In Part 5, we’ll talk about the specific requirements for different actors across the value chain and explore how collaboration and shared accountability can drive effective compliance and sustainability under ESPR
📚 Explore the series at your own pace.
Part 1: What you need to know about ESPR
Part 2: Horizontal rules under ESPR
Part 3: Sustainable discarding and destruction of products under ESPR
Part 5: Specific ESPR requirements for manufacturers, importers, distributors, and retailers
Part 6: Why stakeholder collaboration matters for ESPR compliance
Part 7: Turning compliance challenges into opportunities with ESPR
This is Part 3 of the series "Get Ready for ESPR: Shaping the Future of Sustainable Business."
This article dives into the rules around the discarding and destruction of unsold products under the Ecodesign for Sustainable Products Regulation (ESPR). As part of the EU’s ongoing sustainability efforts, businesses are encouraged to shift away from wasteful destruction practices and instead prioritise circular economy strategies such as reusing, refurbishing, or donating unsold goods. We will also examine the upcoming regulations on product destruction and the steps businesses can take to comply, reduce environmental impact, and foster a circular economy.
Under the ESPR, businesses must focus on reuse, refurbishment, or donation of unsold products rather than discarding them. If a business does discard products, it must provide detailed information about the discarded items, including:
Businesses must report the number and weight of discarded products.
The reason for discarding the products should be clearly stated (e.g., unsold, damaged, outdated).
Information on how the discarded products are being handled, including:
This information must be made publicly available on the company’s website and included in its annual sustainability report.
Businesses must ensure that the information is transparent and accessible. Medium-sized enterprises are required to comply with these disclosure requirements by 19 July 2030. While micro and small enterprises are currently exempt, they are encouraged to already adopt sustainable practices.
It is important to know that the European Commission or national authorities may request further documentation regarding the handling of discarded products. Businesses must provide this documentation within 30 days of the request. The appropriate formats for disclosure will be provided by the European Commission on 19 July 2025.
The ESPR prohibits the destruction of certain unsold products starting 19 July 2026, with specific rules applying to apparel and footwear. This prohibition aims to reduce waste and encourage the donation, reuse, or recycling of unsold goods.
The affected products include the following:
These rules apply to medium-sized enterprises from 19 July 2030. Micro and small enterprises are exempt for now but are still encouraged to avoid destroying products.
There are several exemptions to the destruction ban, including:
The European Commission may also add other exemptions by 19 July 2025.
To comply with ESPR rules on discarding and destruction of products, businesses should take proactive steps:
By adopting these measures now, businesses can stay ahead of ESPR requirements and contribute to reducing waste while promoting circularity in their operations.
By prioritising reuse, refurbishment, and donation over destruction, businesses can reduce waste, align with EU sustainability goals, and foster circularity. The ESPR encourages businesses to adopt sustainable practices in product disposal and to provide transparency in handling discarded products. As the regulations evolve, businesses must stay proactive in meeting compliance requirements to minimise environmental impact and contribute to a more sustainable economy.
In Part 4, we’ll show you how digital product passports (DPPs) enhance traceability and transparency, and how they can support your sustainability goals.
📚 Explore the series at your own pace.
Part 1: What you need to know about ESPR
Part 2: Horizontal rules under ESPR
Part 4: ESPR enhances traceability and transparency with digital product passports
Part 5: Specific ESPR requirements for manufacturers, importers, distributors, and retailers
Part 6: Why stakeholder collaboration matters for ESPR compliance
Part 7: Turning compliance challenges into opportunities with ESPR
This is Part 2 of the series "Get Ready for ESPR: Shaping the Future of Sustainable Business."
The horizontal rules in the ESPR set the foundation for product sustainability, aiming to improve the durability, reparability, and recyclability of products while reducing their overall environmental impact. Applicable across different product categories, these rules create a uniform standard that ensures products meet sustainability requirements at various stages of their lifecycle.
Here are the key horizontal rules that must be considered under the ESPR:
Products must be designed to last longer, reducing the need for frequent replacements and contributing to a reduction in waste. Durable products are essential for supporting circular economy practices by ensuring that products are used for longer periods, reducing the overall consumption of resources.
Reliability ensures that products perform as expected over time, reducing the frequency of product failures and minimising waste associated with defective or non-functioning products.
Designing products for reuse is critical to promoting circularity. Reusable products can be easily repaired, refurbished, or repurposed, reducing the demand for new raw materials and minimising waste.
Products should be designed in a way that allows for easy upgrades. This is particularly relevant for electronics and technology, where products can be improved with newer software or hardware, extending their useful life and reducing the need for complete replacements.
Repairability is a key factor in reducing waste and increasing product lifespan. Products should be designed to allow easy repair, with accessible spare parts, repair manuals, and modular components. The JRC report suggests that repairability standards should be harmonised to make it easier for consumers and businesses to repair products, reducing waste and improving sustainability.
Products should be designed with materials that are easily recyclable, ensuring that when the product reaches the end of its life, its components can be effectively recovered and reused. This includes the use of recyclable materials and design strategies that facilitate disassembly.
Incorporating post-consumer recycled content into products helps reduce the demand for virgin materials, conserving natural resources and supporting the recycling industry. The JRC report highlights the importance of promoting the use of recycled materials as part of the EU’s broader sustainability goals.
Products should be designed to allow for maintenance and refurbishment, enabling them to be restored to their original function. This helps extend the product's life and reduces the environmental impact associated with the disposal and production of new products.
Energy use is a critical factor in product design. Products must be designed to minimise energy consumption during their lifecycle, including production, use, and disposal phases. Energy-efficient products contribute to reducing carbon emissions and lowering the environmental footprint of the product.
Reducing water use in product manufacturing and use phases is vital for ensuring the sustainability of resources. Products should be designed to minimise water consumption and maximise water efficiency throughout their lifecycle.
Efficient use of resources involves designing products that minimise the extraction and consumption of raw materials. Products should be designed to use fewer resources while maintaining their functionality and quality, reducing waste and conserving natural resources.
Products should be designed in a way that allows them to be remanufactured, extending their lifecycle and contributing to the circular economy. This involves creating products that can be disassembled, cleaned, and reassembled to restore them to a functional state.
Designing products for material recovery ensures that valuable materials can be extracted and reused at the end of a product’s life. This reduces the need for new raw materials and supports a more sustainable approach to resource management.
A product’s environmental impact, including its carbon footprint, should be minimised. The design process should focus on reducing emissions and the overall environmental footprint of the product throughout its lifecycle.
Products should be designed to minimise the generation of waste during production, use, and disposal. Reducing waste at all stages of the product lifecycle is essential for a circular economy.
The presence of hazardous substances, such as toxic chemicals or materials that hinder recycling, must be monitored and controlled. Products should be free from substances that can negatively impact health, the environment, or recycling processes.
To effectively implement the horizontal rules under the Ecodesign for Sustainable Products Regulation (ESPR), follow these instructions to ensure your products meet the required sustainability standards and contribute to the EU’s circular economy goals.
To facilitate easier compliance, ensure that your products meet standardised criteria for repairability and recyclability. Develop consistent product design specifications that support easy repairs, access to spare parts, and simple disassembly for recycling. Align these standards across your product lines to ensure uniformity in your sustainability practices.
Ensure that your products feature clear and easy-to-understand labels that communicate essential sustainability information. This includes data on the product's repairability, energy efficiency, recyclability, and environmental footprint. Clear labelling will help consumers and businesses make informed decisions based on sustainability features and contribute to better compliance with ESPR.
Develop and implement standardised metrics to assess and report on key circular economy aspects, such as resource efficiency, material recovery, and carbon footprint. These metrics will help you track the environmental impact of your products, report progress on sustainability goals, and ensure compliance with the ESPR’s resource use and recycling requirements.
Drive innovation in your product design by focusing on areas like product modularity, energy efficiency, and the use of sustainable materials. Look for opportunities to exceed the minimum ESPR requirements and introduce circular business models that reduce waste, improve energy efficiency, and use renewable resources. Offering incentives for innovation can help your company stay ahead of regulatory changes and lead the way in sustainability.
In Part 3, we’ll dive into the details of the regulations on discarding and destruction of products under ESPR.
📚 Explore the series at your own pace.
Part 1: What you need to know about ESPR
Part 3: Sustainable discarding and destruction of products under ESPR
Part 4: ESPR enhances traceability and transparency with digital product passports
Part 5: Specific ESPR requirements for manufacturers, importers, distributors, and retailers
Part 6: Why stakeholder collaboration matters for ESPR compliance
Part 7: Turning compliance challenges into opportunities with ESPR
