News and updates from national and European regulators continue to be an integral part of our newsletter. In this issue, you can expect (once again) a new regulatory proposal in the plastics sector, information and practical help on the PPWR as well as insights into the resurgent debates on CSRD, EU Taxonomy and CSDDD.
Yet another new regulatory proposal in the plastics sector
In October 2024, the EU Parliament adopted its position of April 2024 on the European Commission’s draft “preventing plastic pellet losses to reduce microplastic pollution”. At the same time, the regulation was tightened up in various places. It proposed, for example, to:
- extend the scope of the regulation to small companies,
- establish regular verification through certifications and
- consider the existing contamination from plastic granulate.
With Parliament’s position, negotiations between the Council, Parliament and Commission can now begin. We will keep you up to date.
You can download the “Proposal for a Regulation of the European Parliament and of the Council on on preventing plastic pellet losses to reduce microplastic pollution” as a PDF here.
PPWR: It’s here. What now?
The new European Packaging and Packaging Waste Regulation (PPWR) is finally here. The regulation was proposed by the European Commission in November 2022 and has been a work in progress ever since. It introduces a wide range of binding requirements and targets aimed at reducing packaging waste and promoting recycling, reuse and sustainability.
Formally adopted by the European Council on 16 December 2024, the PPWR was published in the Official Journal of the EU on 22 January 2025 and came into force on 12 February 2025. After an 18-month transition period, the first requirements of the regulation will therefore apply from 12 August 2026. Nevertheless, you still need to take action now.
For an initial overview, we recommend our PPWR white paper.
What to do now
All companies in the supply chain must start their preparations now at the latest! From 12 August 2026, all packaging elements and components must be accompanied by a technical conformity assessment in accordance with Articles 15 & 16 and the model in Annex VII and VIII.
Even though most of the requirements of the PPWR will not come into force until January 2030, some will already apply from August 2026. This applies to the requirements from Chapter 5, such as the PFAS restrictions.
You should also bear in mind that the documentary effort required to prepare the technical conformity assessment is considerable.
- You need to set up efficient and digitalised solutions to integrate your suppliers. For this, you need their technical documents so that you can process them accordingly in the second step.
- At the same time, you need to compile the right information for your customers.
The short answer to the question of what to do now: Let’s get to work together and prepare your company for the start of PPWR. Do your PPWR impact check here – and get in touch with us.
CSRD, CSDDD, EU Taxonomy: Why is an omnibus coming round the corner?
The new year is not even old yet, and already there is a lot of discussion about how and where regulations for European sustainability reporting should, could or should be changed again. In this context, Commission President Dr. Ursula von der Leyen has announced an ominous omnibus that is supposed to make everything better, faster and less bureaucratic in sustainability reporting.
The omnibus procedure
An omnibus procedure attempts to summarise and streamline different laws, regulations etc. in one act. The aim is, for example, to remove duplications and uncover contradictions between the individual laws. As a result, clear and transparent rules and definitions are sought, which then apply to all laws in the omnibus. The targeted omnibus is to contain the following legislative packages: Corporate Sustainability Reporting Directive (CSRD), EU Taxonomy and the European Supply Chain Directive (CSDDD).
Background
The move comes at a time of increasing pressure for regulatory simplification. Data shows that more than 60 per cent of EU companies see regulation as an obstacle to investment. For SMEs, the challenge is particularly acute: 55 per cent of small and medium-sized enterprises see regulation and the resulting administrative burden as their biggest challenge.
Concrete expectations
Pending a clear announcement from the Commission, speculation was fuelled as to what the omnibus legislation might focus on. Ideas for further regulatory changes emerged. These include, among others:
- limiting the group of companies affected (raising the limit from 250 to 500 employees)
- the reduction of the extraterritorial effect
- the postponement of the CSRD application deadlines
- the abolition or interruption of the development of new sector-specific reporting standards
- the reduction in the number of data points required
When will the omnibus legislative process start?
The Commission’s legislative proposal was due to be published on 26 February 2025. The legislative process, which also involves the European Council and the European Parliament, must run its course before the omnibus legislation is finalised and enters into force.
The length of the legislative process will depend on several factors, including the complexity of the proposed amendments. The relatively isolated amendments to the EU Deforestation Regulation, which came into force on 26 December 2024, took around three months (after the Commission proposed the amendments).
Will the high standards and ambitious targets be maintained?
The EU Commissioner responsible for trade, Valdis Dombrovskis, recently said that “simplification does not mean deregulation”. However, his statement has not dampened speculation in the industry, not least due to dissenting voices from the Commission. The latter had raised the question of whether the omnibus legislation should not also lower the EU’s required social and environmental standards.
What does that mean for you?
Does this mean yes or no to formal sustainability reporting for companies? In the view of BP Consultants, it continues to make economic sense for every company to deal with the opportunities and risks that can be summarised under the generic term ESG, because:
- climate change, supply chain risk, skills shortages, digitalisation, new climate-friendly products and the circular economy are issues that are not going to go away (whether you like it or not),
- banks will ask for transparent KPIs and
- customers will demand traceable targets and verifiable product carbon footprints.
- EcoVadis also demands many points that are queried as part of the CSRD. These include materiality analyses, GHG inventories and climate targets.
Above all, it is also clear that politics is increasingly taking place in the rhythm of the legislature. However, a sustainable company should think much more long-term.
We are happy to help you find pragmatic and efficient solutions for your customised sustainability reporting. Just get in touch with us!
