Over the past two years, EU sustainability regulations have been associated almost exclusively with the reporting obligations under the Corporate Sustainability Reporting Directive (CSRD). In 2026, that picture is changing. Reporting obligations are being scaled back, while a range of product-and supply-chain-level regulations are simultaneously coming into force, with direct consequences for companies’ day-to-day operations.
Below we present the four changes most relevant today for companies present on the EU market or trading with the EU, as well as for their advisors.
- PPWR: A comprehensive packaging reform enters into force on 12 August 2026
Of the regulations ahead, Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40 requires action the soonest. It entered into force in February 2025, and from 12 August 2026 it will apply across all 27 EU Member States, replacing the packaging directive (94/62/EC), over 30 years old, with a single, harmonised set of rules for the whole European Union.
A common regulatory framework across the EU
The new legal framework changes how packaging rules are applied across the EU. The previous directive gave Member States discretion in implementation, which for years led to divergences between packaging rules across EU countries. The PPWR leaves no such discretion, applying directly, in identical form and from the same date, across the whole Union. For companies in manufacturing, import and distribution, this is one of the most significant regulatory changes of the past decade. In other words, from that date, packaging compliance becomes a precondition for legally placing a product on the EU market.
What changes as of August 2026?
From 12 August 2026, companies must hold documentation confirming packaging compliance with the PPWR, including the EU Declaration of Conformity and Technical Documentation, and must ensure compliance with PFAS and heavy metal limits. For importers from outside the EU, it will also be essential to appoint an authorised representative for Extended Producer Responsibility (EPR) in each Member State to which they export.
PPWR will be rolled out in stages
In the coming years, further requirements will follow, including mandatory packaging labelling, deposit-return system requirements, recyclability rules, restrictions on empty space in e-commerce packaging, and reuse targets for selected packaging types. The key year among these will be 2030, when the recyclability classification of packaging will affect whether products can be placed on the market and packaging design will begin to influence the EPR fees payable.
What should a company do now?
- Carry out a packaging audit: composition, weight, volumes, suppliers;
- check whether suppliers hold up-to-date documentation and certificates;
- assess PFAS and heavy metal risk;
- determine the company’s role in the supply chain: producer, importer, distributor, EPR entity;
- identify which packaging may require changes before 2030.
Non-compliance will result in sanctions and restrict access to sales channels, particularly as retail chains and distributors increasingly require packaging documentation as a condition of cooperation.
- EUDR: A ban on selling deforestation-linked products from 30 December 2026
The EU Deforestation Regulation (EUDR) is an EU regulation blocking the sale in the EU of products linked to deforestation. It covers seven commodities, including cattle, cocoa, coffee, palm oil, rubber, soy and wood, plus everything derived from them, such as chocolate, leather or furniture. The regulation uses 31 December 2020 as a fixed cut-off date for assessing the land on which these commodities were produced. Where that land was deforested after this date, products made from the resulting raw materials cannot be placed on the EU market, even if they otherwise meet the applicable quality and safety requirements.
New deadline: 30 December 2026
The regulation will take effect from 30 December 2026, and for smaller companies that already had micro or small enterprise status at the end of 2024, the deadline is pushed back by an additional six months, to 30 June 2027.
A company’s place in the supply chain determines the scope of its obligations
What matters most here is a company’s position in the supply chain. The full burden of proving a raw material’s origin falls primarily on the first link, the company that first places the raw material or product on the EU market. Companies further down the chain have a much lighter task, provided their suppliers have already completed the required formalities.
First steps before December 2026
A good starting point is determining whether the company is that first link and beginning to collect basic information on raw material origin from suppliers, usually the most time-consuming stage of the whole process.
Non-compliance with the EUDR can create serious commercial obstacles in addition to potential sanctions. Retail chains and distributors are increasingly asking suppliers to provide documented evidence of raw material origin, even where this goes beyond their own legal obligations, as they seek to avoid working with companies whose goods could be withdrawn from the market.
- CBAM: The CO₂ border mechanism enters its definitive phase from 1 January 2026
The Carbon Border Adjustment Mechanism (CBAM) (Regulation (EU) 2023/956) requires importers of energy-intensive goods from outside the EU to pay for the CO₂ emissions generated in their production, just as producers operating within the Union do under the European Union Emissions Trading System (EU ETS.) The aim is to level the playing field and discourage moving production outside the EU purely to avoid emissions costs. The regulation entered into force in May 2023, and from 1 October 2023 a transitional period based solely on reporting applied. That phase ends on 1 January 2026. From that date, importing goods covered by CBAM already requires authorised declarant status. The regulation covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity.
The bill is delayed, but unavoidable
Certificate sales will begin in February 2027 and will cover emissions embedded in imports from 2026, with the first deadline for declarations and certificate surrender set for 30 September 2027.
50 tonnes a year: The CBAM exemption threshold
Importers whose total annual mass of goods covered by CBAM (iron and steel, aluminium, cement, fertilisers) does not exceed 50 tonnes are exempt from the regulation’s obligations. The exemption does not apply to electricity or hydrogen.
Preparing emissions data for CBAM in 2026
The practical task for importers in 2026 is collecting emissions data from suppliers and forecasting costs, not yet purchasing certificates. Actual data from suppliers remains more advantageous than default values, which carry an increasing surcharge.
Non-compliance with CBAM means being unable to import without authorised declarant status, and in the case of violations, financial penalties and the risk of having that authorisation revoked.
- Banks: EBA guidelines on ESG risks are changing how credit is granted
Although this might seem like a matter solely for the banking sector, in practice it affects virtually every company applying for a loan. The European Banking Authority’s guidelines on the management of ESG risks (EBA/GL/2025/01) apply to banks from 11 January 2026.
Banks must treat ESG risks as financial risks embedded in credit assessment and risk appetite, not merely as a reputational issue. Transition risk and physical risk (e.g. flood exposure affecting the value of collateral) must therefore be taken into account when assessing a borrower’s creditworthiness, and banks must have their own transition plans.
For clients, this means a concrete change: the bank must collect ESG data from them within the scope set out in the guidelines (including greenhouse gas emissions, water use, energy intensity indicators.) In many European countries, the banking sector has already begun standardising ESG questionnaires for clients, typically in a full version aligned with ESRS, and a simplified version based on the VSME standard for smaller companies.
This is probably the most cross-cutting item on this list, in practice it can affect almost any company seeking bank financing, although banks tailor the scope of questions to a client’s scale and risk profile.
Four key regulations for 2026
PPWR, EUDR, CBAM and the EBA guidelines on ESG risks differ in scope and in who they target, but they share one thing: they all genuinely start applying within the same tight window, from August 2026 to mid-2027. For a company placing packaging on the market, importing raw materials, bringing in energy-intensive goods, or relying on bank financing, this means several overlapping deadlines at once, not a single change.
The biggest risk is treating them separately, that’s when the same data ends up being collected multiple times, wasting time that, with so many deadlines running in parallel, simply isn’t there to spare.
A good starting point is one question: which of these regulations apply to our company, and in what order should we address them.
This article was prepared by ETL GLOBAL Member in Poland SWGK. Learn more about their services and contact the team for further assistance.
