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Regulatory observatory · continuously updated

ESG, packaging and sustainability regulations:
deadlines and obligations 2021–2040

CSRD, Omnibus, PPWR, CBAM, EUDR, ecodesign, green buildings, RENTRI: more than thirty European and Italian rules that are changing the way companies produce, sell, package and report. We have lined them up, from the first deadline to the last, together with what each business actually needs to do.

The observatory in numbers
44
regulations monitored
regulations, directives and national laws
18
deadlines in the next 12 months
calculated from today's date
30
key deadlines on the calendar
milestones that trigger obligations
41
year horizon
from the first rule to climate neutrality in 2050

Upcoming deadlines

The milestones coming up first, in date order. Each card opens the full factsheet for the regulation.

The complete map, from 2021 to 2040

Each row is a regulation: the bar runs from publication to the last known deadline, and the diamonds mark the dates on which obligations apply. Click a bar or a diamond for the detailed factsheet; filter by area, status or keyword.

Regulation
2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 Today
Reporting and sustainable finance
Packaging and circular economy
Products, ecodesign and consumers
Climate, energy and emissions
Supply chain and due diligence
Labour, governance and standards
EU–China: trade and investment
EU–Japan: trade and sustainability
Italy: national requirements

Drag or scroll horizontally to move through time

Packaging: the timetable of the new regulation

Regulation (EU) 2025/40 on packaging and packaging waste replaces the Packaging Directive and applies directly, without transposition, to anyone who manufactures, imports, fills or distributes packaging in the EU. Substances, recyclability, recycled content, reuse and labelling: here are the milestones and figures you need to know.

Minimum recycled content in plastic packaging
20302040
Contact-sensitive plastic, PET 50%30%
Contact-sensitive plastic, non-PET 25%10%
Single-use beverage bottles 65%30%
Other plastic packaging 65%35%
Reuse targets for 2030 and 2040
20302040
Transport packaging 70%40%
Beverages (certain categories excluded) 40%10%
Multipack and grouped packaging 25%10%
Reduction in packaging waste per capita (compared with 2018)
−5%2030
−10%2035
−15%2040
50% maximum empty space ratio in grouped, transport and e-commerce packaging, from 2030
90% separate collection of single-use plastic bottles and cans, with a deposit return scheme from 2029
A·B·C recyclability grades: from 2030 packaging below grade C is banned from the market, and from 2038 grade C as well

The timeline of key deadlines

Only the decisive milestones, grouped by year. Select a year to jump straight to it.

2019
2022
2023
2024
2025
2026 We are here
2027
2028
2029
2030
2040

What each regulation requires, and what to do

For each regulation: official reference, status, obligated parties, deadlines and practical compliance steps.

Reporting and sustainable finance

Reporting and sustainable finance Phased application

CSRD — Corporate Sustainability Reporting Directive

Directive (EU) 2022/2464 · Legislative Decree 125/2024 · Directive (EU) 2025/794 "Stop-the-clock" and Omnibus I

Requires companies to publish sustainability information in their management report in accordance with the ESRS, based on double materiality and subject to external assurance. Following the 2025 "Stop-the-clock" Directive, the waves after the first were postponed by two years; the Omnibus I package then narrowed the obligation to companies with more than 1,000 employees and more than €450 million in net turnover, excluding listed SMEs.

Next milestone 1 Jan 2027 · in 68 days Financial year 2027: obligation for large companies within the new scope (first report in 2028)
Details and deadlines
Who it applies to

First wave: large public-interest entities already subject to the NFRD (Italian DNF). After Omnibus: EU companies with more than 1,000 employees and more than €450 million in turnover; non-EU groups with more than €450 million in EU revenue. SMEs in the value chain are protected by the information cap set by the voluntary VSME standard.

What to do
  • Check your position against the new Omnibus thresholds and your first reporting year
  • Set up the double materiality assessment and ESG data collection with traceable processes and controls
  • Prepare data and answers for obligated customers, using the VSME as a common basis
  • Plan the auditor's limited assurance and the digital tagging (XBRL) of the report
Deadlines
  1. Entry into force of the CSRD
  2. First wave: entities already subject to the NFRD report from financial year 2024 (reports published in 2025)
  3. Legislative Decree 125/2024 transposing the CSRD in Italy enters into force
  4. "Stop-the-clock" Directive: two-year postponement for the second and third waves
  5. Final adoption of the Omnibus I package: new thresholds of 1,000 employees and €450 million
  6. Financial year 2027: obligation for large companies within the new scope (first report in 2028) in 68 days
  7. Indicative deadline for national transposition of the Omnibus amendments in 127 days
  8. Financial year 2028: obligation for non-EU groups with more than €450 million in EU revenue in 433 days
Reporting and sustainable finance Phased application

ESRS — European Sustainability Reporting Standards

Commission Delegated Regulation (EU) 2023/2772 and subsequent EFRAG revisions

They define what to report and how under the CSRD: two cross-cutting standards (ESRS 1 and 2) and ten topical standards, from E1 Climate change to G1 Business conduct. At the request of the Commission, EFRAG delivered a simplified version at the end of 2025, with a sharp reduction in mandatory datapoints and a leaner double materiality assessment.

Next milestone 1 Jan 2027 · in 68 days Application of the simplified ESRS from financial year 2027
Details and deadlines
Who it applies to

All companies subject to the CSRD; in practice, also suppliers that are asked for environmental and social data.

What to do
  • Map the datapoints already available against the simplified ESRS
  • Prioritise climate (E1): Scope 1, 2 and, where material, Scope 3 emissions
  • Document the materiality assessment process for the auditor
Deadlines
  1. Publication of the first set of ESRS in the Official Journal
  2. "Quick fix": the Commission extends the phase-in reliefs for first-wave companies
  3. EFRAG delivers the simplified ESRS to the Commission
  4. Commission delegated act on the revised ESRS (expected)
  5. Application of the simplified ESRS from financial year 2027 in 68 days
Reporting and sustainable finance In force

VSME — Voluntary Sustainability Reporting Standard for SMEs

Commission Recommendation of 30 July 2025 · EFRAG VSME standard

A voluntary, proportionate standard designed for unlisted SMEs: a Basic Module and a Comprehensive Module that respond to requests from banks, investors and large customers. Under Omnibus it becomes the "cap" on the information that obligated companies may request from smaller suppliers.

Next milestone 1 Jan 2027 · in 68 days The VSME becomes the information cap for the value chain of CSRD companies
Details and deadlines
Who it applies to

SMEs and companies with up to 1,000 employees that want (or need, for their customers) to disclose ESG data.

What to do
  • Draft a first VSME Basic Module report to share with banks and customers
  • Collect energy, emissions, waste, water and workforce data on an ongoing basis
  • Use it as an award criterion in tenders and financing applications
Deadlines
  1. EFRAG publishes the VSME standard
  2. The Commission adopts the Recommendation on the VSME
  3. The VSME becomes the information cap for the value chain of CSRD companies in 68 days
Reporting and sustainable finance In force

EU Taxonomy for sustainable activities

Regulation (EU) 2020/852 · Climate, Environmental and 2025 Simplification Delegated Acts

Classifies environmentally sustainable economic activities against six environmental objectives. CSRD companies disclose the proportion of eligible and aligned turnover, CapEx and OpEx. The Simplification Delegated Act introduces a 10% materiality threshold and reduced reporting templates.

All milestones have already passed
Details and deadlines
Who it applies to

Companies subject to the CSRD, banks and asset managers; indirectly, those applying for green finance or taking part in calls for funding subject to the DNSH principle.

What to do
  • Check which activities are eligible and aligned with the technical screening criteria
  • Apply the DNSH principle to funded investments and projects (Italian NRRP, calls for funding)
  • Link Taxonomy KPIs to investment planning
Deadlines
  1. Entry into force of the Taxonomy Regulation
  2. Application for the climate change mitigation and adaptation objectives
  3. Extension to the other four environmental objectives (water, circular economy, pollution, biodiversity)
  4. Simplification applies: 10% materiality threshold and reduced templates
Reporting and sustainable finance Under negotiation

SFDR — Sustainable Finance Disclosure Regulation

Regulation (EU) 2019/2088 · "SFDR 2.0" review proposal of 20 November 2025

Requires asset managers, insurers and advisers to disclose how they integrate sustainability risks and to classify their products (Articles 6, 8 and 9). The review proposal replaces the articles with three product categories: sustainable, transition and ESG basics.

Next milestone 2028 · in 433 days Possible application of the new rules, following negotiations
Details and deadlines
Who it applies to

Financial market participants; indirectly, companies that receive ESG data requests from funds and banks.

What to do
  • Prepare for ESG questionnaires from investors and lenders
  • Make the principal adverse impact (PAI) indicators available
Deadlines
  1. Application of the Level 1 obligations
  2. Application of the regulatory technical standards (RTS)
  3. The Commission presents the "SFDR 2.0" proposal
  4. Possible application of the new rules, following negotiations in 433 days
Reporting and sustainable finance In force

ESG Rating Activities Regulation

Regulation (EU) 2024/3005

Brings providers of ESG ratings in the EU under ESMA supervision, with transparency obligations on methodologies, sources and conflicts of interest, and separation from other activities.

All milestones have already passed
Details and deadlines
Who it applies to

ESG rating providers; for rated companies, it means clearer methodologies and the ability to report errors.

What to do
  • Review your ratings and the methodologies behind them
  • Keep ESG data public, consistent and up to date
Deadlines
  1. Entry into force of the regulation
  2. Application: rating providers must be authorised by ESMA
Reporting and sustainable finance In force

European Green Bond Standard (EuGB)

Regulation (EU) 2023/2631

A voluntary label for green bonds: at least 85% of the proceeds must be allocated to Taxonomy-aligned activities, with an external review by a reviewer registered with ESMA.

All milestones have already passed
Details and deadlines
Who it applies to

Companies and entities that issue bonds or finance green projects.

What to do
  • Consider the EuGB label for financing transition projects
Deadlines
  1. Entry into force
  2. Application of the EuGB standard

Packaging and circular economy

Packaging and circular economy Phased application

PPWR — Packaging and Packaging Waste Regulation

Regulation (EU) 2025/40 on packaging and packaging waste, repealing Directive 94/62/EC

Governs the entire life cycle of packaging: substances, design for recycling, recycled content, minimisation, reuse, labelling and EPR. As a regulation it applies directly in all Member States and introduces the EU declaration of conformity and technical documentation for every item of packaging placed on the market.

Next milestone 12 Feb 2028 · in 475 days HORECA takeaway: obligation to offer customers a reusable alternative
Details and deadlines
Who it applies to

Packaging manufacturers, producers and "packers", importers, distributors, e-commerce and HORECA. No general exemption for SMEs; some derogations for micro-enterprises.

What to do
  • Inventory all packaging (primary, secondary, tertiary) with materials, weights and suppliers
  • Obtain declarations on PFAS and heavy metals from suppliers by August 2026
  • Prepare an EU declaration of conformity and technical file for each item of packaging
  • Redesign packaging for recyclability, recycled content and empty space ahead of 2030
  • Assess reuse systems for transport and B2B packaging and check the banned single-use formats
Deadlines
  1. Entry into force of the regulation
  2. General application: EU declaration of conformity, PFAS limits in food-contact packaging, heavy metals below 100 mg/kg, new obligations for producers
  3. HORECA takeaway: obligation to offer customers a reusable alternative in 475 days
  4. Harmonised EU material label for separate collection in 657 days
  5. Mandatory deposit return scheme for single-use plastic bottles and cans up to 3 litres in 799 days
  6. All packaging recyclable (grades A–C), minimum recycled content, maximum empty space of 50%, bans on single-use formats (Annex V), reuse targets, waste −5% in 1164 days
  7. Recyclability "at scale" and a 10% reduction in packaging waste in 2990 days
  8. Recyclability grade C is also banned from the market in 4086 days
  9. Recycled content of 50–65% in plastic, extended reuse, waste −15% in 4816 days
Packaging and circular economy Phased application

Single-Use Plastics Directive (SUP)

Directive (EU) 2019/904 · Legislative Decree 196/2021

Bans certain single-use plastic products (cutlery, plates, straws, expanded polystyrene containers) and requires tethered caps on bottles, specific markings, recycled content in PET bottles and EPR schemes. For bottles, many of the rules are now being absorbed into the PPWR.

Next milestone 1 Jan 2030 · in 1164 days All beverage bottles with at least 30% recycled plastic
Details and deadlines
Who it applies to

Producers and distributors of beverages, food containers, tobacco products, wet wipes, balloons and fishing gear.

What to do
  • Check banned products and the alternatives permitted in Italy
  • Check bottle markings and recycled content
Deadlines
  1. Market restrictions and marking requirements
  2. Tethered caps mandatory on bottles up to 3 litres
  3. PET bottles with at least 25% recycled plastic
  4. Separate collection target of 77% of bottles (placed on the market in 2025)
  5. All beverage bottles with at least 30% recycled plastic in 1164 days
Packaging and circular economy Forthcoming

Targeted revision of the Waste Framework Directive: textiles and food waste

Directive (EU) 2025/1892, amending Directive 2008/98/EC

Introduces mandatory extended producer responsibility for textiles, clothing and footwear in all Member States, together with binding food waste reduction targets by 2030.

Next milestone Jun 2027 · in 235 days Transposition deadline for Member States
Details and deadlines
Who it applies to

Those placing textile products and footwear on the market (including online and from outside the EU); the food industry, retail and food service.

What to do
  • Prepare to register with textile EPR schemes and for the related eco-modulation
  • Measure food waste and define a reduction plan
Deadlines
  1. Entry into force of the directive
  2. Transposition deadline for Member States in 235 days
  3. Textile EPR schemes operational in all Member States in 540 days
  4. Food waste: −10% in processing and manufacturing, −30% per capita in retail, food service and households in 1528 days

Products, ecodesign and consumers

Products, ecodesign and consumers Phased application

ESPR — Ecodesign for Sustainable Products Regulation and Digital Product Passport

Regulation (EU) 2024/1781

A framework for setting requirements on durability, reparability, recycled content and environmental footprint for almost all physical products, with the Digital Product Passport (DPP). It bans the destruction of unsold clothing and footwear and requires companies to disclose how many unsold products they discard.

Next milestone 2027 · in 219 days First delegated acts with requirements for textiles and steel (expected)
Details and deadlines
Who it applies to

Manufacturers, importers and distributors; the first product groups are steel, aluminium, textiles, furniture, tyres and mattresses. SMEs have longer lead times for the destruction ban.

What to do
  • Check whether your products fall within the 2025–2030 working plan
  • Organise product and supply chain data for the Digital Product Passport
  • Track and reduce unsold goods; prepare the annual disclosure
Deadlines
  1. Entry into force of the regulation
  2. ESPR 2025–2030 working plan with the priority product groups
  3. Large companies begin disclosing discarded unsold products
  4. Ban on destroying unsold clothing and footwear (large companies); EU Digital Product Passport registry
  5. First delegated acts with requirements for textiles and steel (expected) in 219 days
  6. The destruction ban is extended to medium-sized companies in 1363 days
Products, ecodesign and consumers Phased application

Batteries Regulation

Regulation (EU) 2023/1542 · due diligence postponement Regulation (EU) 2025/1561

Covers the entire life cycle of batteries: carbon footprint, recycled content, labelling, removability, digital passport, due diligence on raw materials and EPR. It also applies to companies that incorporate batteries into other products.

Next milestone 18 Feb 2027 · in 116 days Battery passport for industrial, EV and LMT batteries; removable and replaceable portable batteries; QR code
Details and deadlines
Who it applies to

Producers, importers and distributors of portable, industrial, electric vehicle and light means of transport (LMT) batteries, including appliances with built-in batteries.

What to do
  • Register in the producer register and join a collection scheme
  • Update labels, QR codes and design for removability
  • Set up due diligence on cobalt, lithium, nickel and graphite
Deadlines
  1. General application of the regulation
  2. New labelling requirements (capacity, composition, lifetime)
  3. Battery passport for industrial, EV and LMT batteries; removable and replaceable portable batteries; QR code in 116 days
  4. Due diligence obligations on raw materials (postponed by two years) in 297 days
  5. Minimum recycled content: 16% cobalt, 6% lithium, 6% nickel, 85% lead in 1758 days
Products, ecodesign and consumers In force

Empowering Consumers for the Green Transition Directive: an end to greenwashing

Directive (EU) 2024/825, amending the Unfair Commercial Practices Directives

Adds to the list of practices that are always prohibited: generic environmental claims ("eco", "green", "environmentally friendly") that cannot be substantiated, climate neutrality claims based on emissions offsetting, and sustainability labels that are not based on a certification scheme or established by public authorities.

All milestones have already passed
Details and deadlines
Who it applies to

All companies that communicate with consumers: labels, packaging, websites, advertising, social media.

What to do
  • Review environmental claims, labels and marks on products and in communications
  • Remove "carbon neutral" claims based on offset credits
  • Keep evidence (LCA, certifications) for every environmental claim
Deadlines
  1. Entry into force of the directive
  2. Deadline for transposition into national law
  3. The new bans apply throughout the EU
Products, ecodesign and consumers Suspended

Proposed Green Claims Directive

Proposal COM(2023) 166

It provided for prior verification by an independent body of every explicit environmental claim. In June 2025 the Commission announced its intention to withdraw it and negotiations stalled; the rules of Directive 2024/825 remain fully applicable.

All milestones have already passed
Details and deadlines
Who it applies to

Companies that make explicit environmental claims to consumers.

What to do
  • Continue to base every claim on verifiable data, as Directive 2024/825 already requires
Deadlines
  1. The Commission presents the proposal
  2. Announcement of intention to withdraw: negotiations suspended
Products, ecodesign and consumers In force

Right to Repair Directive

Directive (EU) 2024/1799

Requires manufacturers to repair, including outside the warranty period and at a reasonable price, products for which EU law sets reparability requirements (washing machines, refrigerators, vacuum cleaners, smartphones, tablets…). If the consumer opts for repair, the legal guarantee is extended by 12 months.

All milestones have already passed
Details and deadlines
Who it applies to

Manufacturers, importers and distributors of durable consumer goods; repairers.

What to do
  • Organise the repair service, spare parts and indicative prices
  • Prepare the European Repair Information Form
Deadlines
  1. Entry into force of the directive
  2. Application in all Member States
Products, ecodesign and consumers Phased application

New Construction Products Regulation (CPR)

Regulation (EU) 2024/3110

Updates the CE marking of construction products by adding environmental requirements: a combined declaration of performance and conformity, phased disclosure of the climate footprint (GWP) and a Digital Product Passport.

Next milestone 2030 · in 1164 days Phased extension of mandatory environmental indicators
Details and deadlines
Who it applies to

Manufacturers, importers and distributors of construction products.

What to do
  • Prepare for the declaration of performance with environmental indicators (EPD)
  • Follow the harmonised technical specifications for your product
Deadlines
  1. Entry into force of the regulation
  2. General application (coexisting with the previous regulation for standards not yet updated)
  3. Phased extension of mandatory environmental indicators in 1164 days

Climate, energy and emissions

Climate, energy and emissions Phased application

CBAM — Carbon Border Adjustment Mechanism

Regulation (EU) 2023/956 · simplification Regulation (EU) 2025/2083

Applies a carbon price equivalent to the EU ETS price to imports of cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. The definitive regime starts in 2026; the simplification introduced an exemption threshold of 50 tonnes per year per importer, which excludes most SMEs.

Next milestone 1 Feb 2027 · in 99 days Sale of CBAM certificates begins
Details and deadlines
Who it applies to

Importers of CBAM goods above 50 t/year; indirectly, non-EU producers that supply data on embedded emissions.

What to do
  • Calculate imported volumes and check the 50-tonne threshold
  • Obtain authorised CBAM declarant status
  • Collect verified emissions data from foreign suppliers
  • Factor the cost of certificates into prices and contracts
Deadlines
  1. Start of the transitional phase with quarterly reports
  2. Definitive regime: mandatory authorisation, 50 t/year threshold
  3. Deadline for authorisation applications allowing imports to continue
  4. Sale of CBAM certificates begins in 99 days
  5. First annual declaration (2026 emissions) and surrender of certificates in 340 days
  6. End of free ETS allowances for CBAM sectors: full price in 2625 days
Climate, energy and emissions Postponed

ETS2 — Emissions trading for buildings and road transport

Directive (EU) 2023/959, amending Directive 2003/87/EC

Extends carbon pricing to heating and road transport fuels, payable by fuel suppliers, who will pass it on in their prices. The launch of the market has been postponed by one year, to 2028.

Next milestone 1 Jan 2028 · in 433 days Launch of the market and surrender of allowances (postponed from 2027)
Details and deadlines
Who it applies to

Fuel suppliers; indirect impact on company fleets, logistics and building heating.

What to do
  • Estimate the cost impact on fleets and heating
  • Plan electrification and efficiency measures before the launch
Deadlines
  1. Permit requirement and emissions monitoring
  2. First emissions reporting (year 2024)
  3. Launch of the market and surrender of allowances (postponed from 2027) in 433 days
Climate, energy and emissions In force

European Climate Law: −55% by 2030, −90% by 2040

Regulation (EU) 2021/1119 and amendment on the 2040 target

Makes climate neutrality by 2050 and a 55% net reduction in emissions by 2030 compared with 1990 legally binding. The amendment agreed at the end of 2025 sets a −90% target for 2040, with limited use of international credits.

Next milestone 31 Dec 2030 · in 1528 days 2030 target: −55% net emissions
Details and deadlines
Who it applies to

Member States and EU institutions: it is the framework that guides the ETS, CBAM, energy, buildings and transport.

What to do
  • Align the company's transition plan with the 2030 and 2040 pathways
Deadlines
  1. Entry into force of the Climate Law
  2. Adoption of the amendment with the 2040 target
  3. 2030 target: −55% net emissions in 1528 days
  4. 2040 target: −90% net emissions in 5181 days
  5. Climate neutrality in 8833 days
Climate, energy and emissions Phased application

Energy Efficiency Directive (EED)

Directive (EU) 2023/1791

Links company obligations to energy consumption rather than size: an energy audit every 4 years above 10 TJ/year and a certified energy management system above 85 TJ/year. It also provides for reporting by data centres.

Next milestone 11 Oct 2027 · in 351 days Energy management system for companies above 85 TJ/year
Details and deadlines
Who it applies to

Companies with average consumption above 10 TJ/year (approximately 2.8 GWh) over the last three years; data centres above 500 kW.

What to do
  • Calculate average consumption over the last three years, across all energy carriers
  • Plan the energy audit or an ISO 50001 system
  • Include the audit results in the management report
Deadlines
  1. Entry into force of the directive
  2. First reporting by data centres
  3. General transposition deadline
  4. Mandatory energy audit for companies above 10 TJ/year without a management system
  5. Energy management system for companies above 85 TJ/year in 351 days
Climate, energy and emissions Phased application

Energy Performance of Buildings Directive ("green homes")

Directive (EU) 2024/1275

Moves the building stock towards zero emissions: zero-emission new buildings, renovation of the worst-performing non-residential buildings, solar installations on new buildings, and the end of incentives for, and then of, fossil fuel boilers.

Next milestone 31 Dec 2026 · in 67 days Solar mandatory on new public and non-residential buildings over 250 m²
Details and deadlines
Who it applies to

Property owners and managers, construction companies, installers, designers, public bodies.

What to do
  • Survey the energy class of company buildings
  • Plan works and solar installations using available incentives and calls for funding
Deadlines
  1. Entry into force of the directive
  2. Transposition deadline for Member States
  3. Solar mandatory on new public and non-residential buildings over 250 m² in 67 days
  4. New public buildings zero-emission in 433 days
  5. All new buildings zero-emission; 16% of the worst-performing non-residential buildings renovated in 1164 days
  6. 26% of the worst-performing non-residential buildings renovated in 2260 days
  7. Phase-out of fossil fuel boilers in 4816 days
Climate, energy and emissions Phased application

Fluorinated Greenhouse Gases Regulation (F-gas)

Regulation (EU) 2024/573

Progressively phases down HFCs until they are phased out in 2050, with bans on placing on the market refrigeration, air-conditioning and heat pump equipment that uses gases with a high global warming potential.

Next milestone 1 Jan 2027 · in 68 days Bans on self-contained heat pumps and air conditioners with a GWP of 150 or more
Details and deadlines
Who it applies to

Users of refrigeration and air-conditioning systems, installers, producers and importers of equipment.

What to do
  • Inventory the systems and gases used; plan their replacement
  • Check operator certifications and leak records
Deadlines
  1. Entry into force of the regulation
  2. First new bans for equipment using high-GWP gases
  3. Bans on self-contained heat pumps and air conditioners with a GWP of 150 or more in 68 days
  4. Further bans for split systems in 1894 days

Supply chain and due diligence

Supply chain and due diligence Postponed

CSDDD — Corporate Sustainability Due Diligence Directive

Directive (EU) 2024/1760 · Stop-the-clock Directive (EU) 2025/794 · Omnibus I

Requires very large companies to identify, prevent and remedy adverse impacts on human rights and the environment in their own operations and in their supply chain. Omnibus raised the thresholds, focused due diligence on direct business partners and postponed application to 2029.

Next milestone 26 Jul 2028 · in 640 days Transposition deadline for Member States
Details and deadlines
Who it applies to

Companies with more than 5,000 employees and more than €1.5 billion in turnover (and non-EU groups with equivalent EU turnover); their suppliers receive codes of conduct and contractual clauses.

What to do
  • Prepare for ESG questionnaires, audits and clauses requested by large customers
  • Map the social and environmental risks of your suppliers
Deadlines
  1. Entry into force of the directive
  2. "Stop-the-clock": one-year postponement of application
  3. Omnibus I: thresholds of 5,000 employees and €1.5 billion
  4. Transposition deadline for Member States in 640 days
  5. Application of the due diligence obligations in 1005 days
Supply chain and due diligence Postponed

EUDR — EU Deforestation Regulation

Regulation (EU) 2023/1115 · postponements 2024/3234 and December 2025

Prohibits placing on the EU market or exporting from the EU cattle, cocoa, coffee, oil palm, rubber, soya and wood (and derived products: chocolate, furniture, paper, leather…) linked to deforestation after 31 December 2020. It requires geolocation of plots of land and a due diligence statement in the EU information system.

Next milestone 30 Dec 2026 · in 66 days Application for large and medium-sized companies
Details and deadlines
Who it applies to

Operators and traders of any size that place the listed commodities and products on the EU market or export them.

What to do
  • Check which customs codes of your products fall within Annex I
  • Obtain geographical coordinates and proof of legality from suppliers
  • Register with the information system and prepare the statements
Deadlines
  1. Entry into force of the regulation
  2. Original date of application, postponed by one year
  3. Commission review on simplification
  4. Application for large and medium-sized companies in 66 days
  5. Application for micro and small enterprises in 248 days
Supply chain and due diligence Forthcoming

Regulation prohibiting products made with forced labour

Regulation (EU) 2024/3015

Prohibits placing on the EU market, and exporting, products made wholly or partly with forced labour, regardless of company size or origin. Authorities may order the withdrawal and disposal of the goods.

Next milestone 14 Dec 2027 · in 415 days Application of the ban
Details and deadlines
Who it applies to

All economic operators, including e-commerce and importers.

What to do
  • Assess supply chain risks for sensitive countries and sectors
  • Include clauses and checks in supply contracts
Deadlines
  1. Entry into force of the regulation
  2. Commission guidelines and risk database
  3. Application of the ban in 415 days

Labour, governance and standards

Labour, governance and standards Phased application

Pay Transparency Directive

Directive (EU) 2023/970

Strengthens equal pay between women and men: pay ranges in job advertisements, a ban on asking about pay history, workers' right to information and periodic reporting on the gender pay gap, with a joint pay assessment if the gap exceeds 5%.

Next milestone 7 Jun 2027 · in 225 days First pay gap report for companies with at least 150 employees (2026 data)
Details and deadlines
Who it applies to

All employers for transparency; reporting obligation for companies with at least 100 employees.

What to do
  • Define objective, gender-neutral pay criteria for roles and grades
  • Calculate the pay gap before it becomes public
  • Link this work to gender equality certification
Deadlines
  1. Entry into force of the directive
  2. Transposition deadline: information rights and transparency in recruitment
  3. First pay gap report for companies with at least 150 employees (2026 data) in 225 days
  4. First report for companies with 100 to 149 employees in 1686 days
Labour, governance and standards In force

European Accessibility Act for products and services

Directive (EU) 2019/882 · Legislative Decree 82/2022

Sets accessibility requirements for e-commerce, banking services, transport, e-books, terminals and other digital products and services. Micro-enterprises providing services are exempt.

Next milestone 28 Jun 2030 · in 1342 days End of the transitional period for services based on products already in use
Details and deadlines
Who it applies to

Companies that sell online or offer digital services to consumers; device manufacturers.

What to do
  • Check your website and e-commerce against the requirements (standard EN 301 549)
  • Publish the accessibility statement for the service
Deadlines
  1. Entry into force of the Italian transposing decree
  2. Application of the accessibility requirements
  3. End of the transitional period for services based on products already in use in 1342 days
Labour, governance and standards Phased application

Revision of ISO 14001 and ISO 9001 and climate change

ISO/IAF 2024 Amendment · ISO 14001:2026 · ISO 9001:2026

Since 2024 all management system standards have required organisations to determine whether climate change is a relevant issue. In 2026 the new editions of ISO 14001 and ISO 9001 are released, with a transition period of around three years for certified organisations.

Next milestone Apr 2029 · in 889 days Indicative end of the transition for ISO 14001
Details and deadlines
Who it applies to

Organisations that are certified or wish to become certified, particularly in order to take part in tenders.

What to do
  • Include climate in the analysis of context and risks
  • Plan the transition to the new editions with your certification body
Deadlines
  1. "Climate action" amendment to all management system standards
  2. Publication of the new ISO 14001:2026
  3. Publication of the new ISO 9001:2026 (expected)
  4. Indicative end of the transition for ISO 14001 in 889 days

EU–China: trade and investment

EU–China: trade and investment In force

FSR — Foreign Subsidies Regulation (foreign subsidies distorting the internal market)

Regulation (EU) 2022/2560

Allows the Commission to investigate financial contributions granted by non-EU countries (subsidies, soft loans, guarantees, capital injections) to companies active in the EU. It requires prior notification of significant concentrations and of bids in high-value public procurement procedures.

All milestones have already passed
Details and deadlines
Who it applies to

Companies of any nationality, including Chinese companies and their consortia, that bid in EU public tenders with an estimated value of €250 million or more, or acquire EU companies with EU turnover of at least €500 million.

What to do
  • Map the financial contributions received from non-EU states over the last three years
  • Check the notification thresholds before submitting bids or closing acquisitions
  • Prepare the declaration or notification to be attached to the tender bid
Deadlines
  1. Regulation enters into force
  2. Application: the Commission can open ex officio investigations
  3. Notification obligation for concentrations and public tenders above the thresholds
  4. Commission report on the functioning of the Regulation
EU–China: trade and investment In force

IPI — International Procurement Instrument

Regulation (EU) 2022/1031

Enables the EU to restrict access to European public procurement for companies and products from countries that do not offer reciprocal access to European companies. The first measure, adopted in 2025, excludes Chinese medical devices from tenders worth more than €5 million.

All milestones have already passed
Details and deadlines
Who it applies to

Economic operators and products originating in countries subject to IPI measures; EU contracting authorities; European companies using components from those countries in their bids.

What to do
  • Check the origin of the products offered in tenders in the affected sector
  • Assess alternative partners and supply chains for tenders above the threshold
Deadlines
  1. Regulation enters into force
  2. First measure: medical devices of Chinese origin excluded from tenders above €5 million
EU–China: trade and investment Phased application

China: sustainability reporting by listed companies and national standards

Shanghai, Shenzhen and Beijing Stock Exchanges Guidelines for Sustainability Reporting (April 2024) · Ministry of Finance Basic Standard for Corporate Sustainability Disclosure (December 2024)

China's three stock exchanges have introduced sustainability reporting guidelines based on double materiality, mandatory for major listed companies (SSE 180, STAR 50, SZSE 100 and ChiNext indices, and dual-listed companies), with the first reports covering financial year 2025. The Ministry of Finance has published the Basic Standard for a national disclosure system, to be completed by 2030.

Next milestone 2030 · in 1164 days Target: unified national system of disclosure standards
Details and deadlines
Who it applies to

Chinese companies listed on the main indices; by cascade, their suppliers, including Italian and European ones, which are asked for environmental and social data.

What to do
  • Prepare for ESG data requests from listed Chinese customers
  • Align data already collected for the CSRD and VSME with Chinese requirements
Deadlines
  1. The Shanghai, Shenzhen and Beijing stock exchanges publish the guidelines
  2. Guidelines enter into force
  3. The Ministry of Finance publishes the Basic Standard for Corporate Sustainability Disclosure
  4. Deadline for the first mandatory reports (financial year 2025)
  5. Target: unified national system of disclosure standards in 1164 days
EU–China: trade and investment Phased application

China's national emissions trading market and "dual carbon" goals

State Council Interim Regulations on the Administration of Carbon Emissions Trading (2024)

The national carbon market, launched in 2021 with the power sector, is the world's largest by emissions covered and from 2025 extends to steel, cement and aluminium. It supports China's goals of peaking emissions before 2030 and achieving carbon neutrality before 2060, and shapes the dialogue with the EU CBAM.

Next milestone 2030 · in 1528 days Target: CO₂ emissions peak before 2030
Details and deadlines
Who it applies to

Large Chinese installations in the covered sectors; indirectly, European importers and companies with production in China.

What to do
  • Monitor installation emissions using methods compatible with CBAM
  • Document the carbon price paid in China for discussions with EU importers
Deadlines
  1. National market launched with the power sector
  2. State Council Interim Regulations enter into force
  3. Extension to steel, cement and aluminium
  4. Target: CO₂ emissions peak before 2030 in 1528 days
  5. Target: carbon neutrality before 2060 in 12486 days

EU–Japan: trade and sustainability

EU–Japan: trade and sustainability In force

EU–Japan Economic Partnership Agreement

Council Decision (EU) 2018/1907 · Protocol on cross-border data flows

The EU's largest bilateral trade agreement: it eliminates most tariffs between Europe and Japan, recognises European geographical indications, opens up public procurement and eases technical barriers. To obtain the preferential tariff, the exporter must prove origin through a statement on origin or the importer's knowledge. An additional protocol safeguards data flows between the two economies.

All milestones have already passed
Details and deadlines
Who it applies to

Italian exporters to Japan (agri-food, wine, fashion, machinery, chemicals) and Japanese companies selling in Europe.

What to do
  • Check the rule of origin for your product and the applicable preferential tariff
  • Prepare the statement on origin and keep the supporting documentation
  • Make the most of geographical indication protection in your commercial strategy
Deadlines
  1. Entry into force of the agreement
  2. Entry into force of the protocol on cross-border data flows
EU–Japan: trade and sustainability Forthcoming

Japan: SSBJ sustainability standards for listed companies

Standards of the Sustainability Standards Board of Japan (March 2025), aligned with ISSB IFRS S1 and S2

In 2025 the Sustainability Standards Board of Japan (SSBJ) published a general standard and a climate standard, aligned with the ISSB standards. The Financial Services Agency plans to make them mandatory on a phased basis for companies on the TSE Prime Market, starting with those with the largest market capitalisation, with external assurance to follow.

Next milestone Mar 2027 · in 157 days Expected obligation for Prime companies with a market capitalisation of at least ¥3 trillion (financial years ending March 2027)
Details and deadlines
Who it applies to

Companies listed on the Prime Market, starting with those with a market capitalisation of at least ¥3 trillion; by extension, European suppliers asked for Scope 3 emissions data.

What to do
  • Prepare for emissions data requests from Japanese customers
  • Reuse data collected for CSRD and VSME in an ISSB-compatible format
Deadlines
  1. Publication of the SSBJ standards
  2. Expected obligation for Prime companies with a market capitalisation of at least ¥3 trillion (financial years ending March 2027) in 157 days
  3. Expected extension to companies with a market capitalisation of at least ¥1 trillion in 523 days
  4. Expected extension to companies with a market capitalisation of at least ¥500 billion in 888 days
EU–Japan: trade and sustainability Phased application

Japan: GX-ETS and “Green Transformation” carbon pricing

GX Promotion Act (2023) and subsequent amendments

Japan's Green Transformation strategy introduces an emissions trading scheme (GX-ETS), launched on a voluntary basis with the GX League and made mandatory for large emitters, a levy on fossil fuels for importers and, later, allowance auctions for the power sector. It is the reference framework for Japanese companies when dealing with the European CBAM.

Next milestone 2028 · in 524 days Expected launch of the fossil fuel levy
Details and deadlines
Who it applies to

Large Japanese emitters (over 100,000 tonnes of CO₂ a year), fossil fuel importers, power generators; indirectly, their European partners.

What to do
  • Align emissions monitoring with the standards required in Japan and by CBAM
  • Assess the impact of carbon pricing on supplies and contracts with Japan
Deadlines
  1. Launch of the voluntary phase with the GX League
  2. Adoption of the GX Promotion Act
  3. Mandatory participation in the GX-ETS for large emitters
  4. Expected launch of the fossil fuel levy in 524 days
  5. Expected launch of allowance auctions for the power sector in 2350 days
EU–Japan: trade and sustainability In force

Japan: Plastic Resource Circulation Act

Plastic Resource Circulation Act (in force since 1 April 2022)

Covers the entire plastics life cycle: eco-friendly product design, reduction of the 12 most common single-use items (cutlery, straws, toothbrushes, hangers and others), and collection and recycling by municipalities and businesses. Anyone supplying at least 5 tonnes of these items a year must adopt reduction measures.

All milestones have already passed
Details and deadlines
Who it applies to

Businesses distributing single-use plastic items in Japan (retail, food service, hotels, dry cleaners), manufacturers and those designing plastic packaging and products for that market.

What to do
  • Review packaging and single-use items intended for the Japanese market
  • Coordinate design with the PPWR to use solutions that work in both markets
Deadlines
  1. Entry into force of the Act

Italy: national requirements

Italy: national requirements Phased application

RENTRI — National electronic waste traceability register

Ministerial Decree no. 59 of 4 April 2023 · Legislative Decree 152/2006, Art. 188-bis

Digitalises waste traceability: registration with the register, a digital waste loading and unloading register and a digital FIR (waste identification form), with a staggered timetable based on size and activity.

All milestones have already passed
Details and deadlines
Who it applies to

Producers of hazardous special waste and of certain non-hazardous waste, carriers, facilities, brokers.

What to do
  • Check your phase and confirm that registration has been completed
  • Switch to the digital register and form, using interoperable software
Deadlines
  1. Registration opens
  2. Registration for producers with more than 50 employees and for waste management operators
  3. Registration for producers with more than 10 employees
  4. Registration for all other obligated parties; digital FIR for everyone
Italy: national requirements In force

CAM (Minimum Environmental Criteria) in public procurement

Legislative Decree 36/2023, Art. 57 · corrective Legislative Decree 209/2024 · sector-specific CAM decrees

Contracting authorities must include the CAM (Minimum Environmental Criteria) in all tenders, as technical specifications and contract clauses and as award criteria. The sector-specific decrees (construction, cleaning, catering, waste, green spaces, furniture…) are updated periodically.

All milestones have already passed
Details and deadlines
Who it applies to

All companies that take part in public tenders.

What to do
  • Know the CAM in force in your sector and the evidence required
  • Highlight certifications, LCAs and EPDs in the technical bid
Deadlines
  1. The new Public Contracts Code takes effect
  2. The corrective decree to the Code enters into force
  3. Ongoing updates to sector-specific CAM decrees
Italy: national requirements In force

Environmental labelling of packaging (Italy)

Legislative Decree 152/2006, Art. 219(5) (introduced by Legislative Decree 116/2020)

All packaging placed on the Italian market must bear the material identification code (Decision 97/129/EC) and, for consumer packaging, information on collection. From August 2028 it will be replaced by the harmonised PPWR label.

Next milestone 12 Aug 2028 · in 657 days Replacement by the harmonised PPWR label
Details and deadlines
Who it applies to

Producers and users of packaging sold in Italy.

What to do
  • Check codes and collection information on all packaging
  • Plan the switch to the future EU label
Deadlines
  1. The obligation enters into force
  2. Replacement by the harmonised PPWR label in 657 days
Italy: national requirements Postponed

Plastic tax and sugar tax

Law 160/2019, Art. 1(634–658) and (661–676) · 2026 Budget Law

A tax of €0.45/kg on MACSI (single-use plastic products) and a tax on sweetened beverages. Introduced in 2020 and postponed several times; the start date is now set at 1 January 2027.

Next milestone 1 Jan 2027 · in 68 days Currently scheduled start date
Details and deadlines
Who it applies to

Manufacturers, importers and purchasers of MACSI from other EU countries; producers and importers of sweetened beverages.

What to do
  • Estimate the weight of virgin plastic in packaging and the cost of the tax
  • Consider recycled and compostable plastic, which are exempt from the tax
Deadlines
  1. Introduced by the 2020 Budget Law
  2. Currently scheduled start date in 68 days
Italy: national requirements In force

Mandatory insurance against natural catastrophes

Law 213/2023, Art. 1(101–111) · Decree-Law 39/2025

Companies with a registered office or permanent establishment in Italy must insure land, buildings, plant and equipment against floods, landslides, earthquakes and overflows. Companies that fail to insure cannot access public grants and incentives.

All milestones have already passed
Details and deadlines
Who it applies to

All companies entered in the Companies Register, with different deadlines by size (agricultural businesses excluded).

What to do
  • Check cover on capital goods
  • Keep the policy: it is a condition for accessing calls for funding and incentives
Deadlines
  1. Obligation for large companies
  2. Obligation for medium-sized companies
  3. Obligation for small and micro enterprises
Italy: national requirements In force

Gender equality certification UNI/PdR 125:2022

Law 162/2021 · UNI/PdR 125:2022 · Legislative Decree 36/2023

A voluntary certification based on six areas of indicators (culture, governance, HR processes, growth opportunities, pay equity, parenthood protection). It entitles companies to a social security contribution relief of up to 1% (maximum €50,000 per year), additional points and a reduced guarantee in tenders.

All milestones have already passed
Details and deadlines
Who it applies to

Companies of all sizes, especially those taking part in tenders or calls for funding.

What to do
  • Carry out a gap analysis against the KPIs of the reference practice
  • Use the certification as a lever in tenders and to obtain the contribution relief
Deadlines
  1. Publication of the UNI/PdR 125 reference practice
  2. Award points in the new Public Contracts Code
Italy: national requirements In force

Whistleblowing: internal reporting channels

Legislative Decree 24/2023 (Directive (EU) 2019/1937)

Requires companies to set up a confidential channel for reporting wrongdoing and to protect whistleblowers from retaliation. It is a governance element also required by the ESRS (G1) and by "Model 231" compliance programmes (Legislative Decree 231/2001).

All milestones have already passed
Details and deadlines
Who it applies to

Private companies with at least 50 employees and those with a Model 231, regardless of headcount.

What to do
  • Set up a confidential channel, which may be digital, and a written procedure
  • Train the person managing the reports
Deadlines
  1. Obligation for companies with at least 250 employees
  2. Obligation for companies with 50 to 249 employees
Italy: national requirements In force

Transizione 5.0 Plan

Decree-Law 19/2024, Art. 38 · implementing Ministerial Decree of 22 July 2024

A tax credit for investment in digital assets that reduce energy consumption by at least 3% at production-facility level or 5% at process level, together with training and renewable energy installations. Investments had to be completed by 31 December 2025.

All milestones have already passed
Details and deadlines
Who it applies to

Companies resident in Italy that invested in 2024–2025.

What to do
  • Keep ex post certifications and documentation for inspections
  • Assess the new measures for investments from 2026
Deadlines
  1. Establishment of the plan
  2. GSE booking platform opens
  3. Deadline for completing eligible investments

The questions we are asked most often

In 2026: general application of the Packaging and Packaging Waste Regulation (PPWR) on 12 August, the ban on generic environmental claims under Directive 2024/825 on 27 September, and the EUDR for large and medium companies on 30 December. In 2027: sale of CBAM certificates from 1 February, the battery passport from 18 February, the first gender pay gap report for employers with at least 150 staff on 7 June, the first annual CBAM declaration on 30 September and, from financial year 2027, CSRD with simplified ESRS for companies with more than 1,000 employees and €450 million turnover.

Reporting continues for companies already subject to the former NFRD and, from financial year 2027, applies to EU companies with more than 1,000 employees and more than €450 million net turnover; from 2028, to non-EU groups with more than €450 million EU turnover. Listed SMEs are out of scope. Smaller companies in the value chain can answer their customers using the voluntary VSME standard.

Regulation (EU) 2025/40 applies from 12 August 2026: packaging needs an EU declaration of conformity and technical documentation, and limits apply to PFAS in food-contact packaging and to heavy metals. Next come the harmonised label (August 2028), deposit return systems for bottles and cans (2029) and, from 2030, mandatory recyclability, minimum recycled content, a 50% empty-space cap, reuse targets and bans on certain single-use formats.

From 2026, importers of less than 50 tonnes a year of CBAM goods (cement, iron and steel, aluminium, fertilisers, hydrogen) are exempt, which excludes most SMEs. Above the threshold, importers need authorised declarant status, emissions data from non-EU suppliers and CBAM certificates, on sale from 1 February 2027.

After two postponements, the EUDR applies from 30 December 2026 to large and medium companies and from 30 June 2027 to micro and small companies. It covers cattle, cocoa, coffee, oil palm, rubber, soya, wood and derived products, which must be deforestation-free after 31 December 2020 and come with geolocation data and a due diligence statement.

The main ones: registration with RENTRI and the digital waste form (for all obliged parties from 13 February 2026), Minimum Environmental Criteria (CAM) in every public tender, environmental labelling of packaging, mandatory natural catastrophe insurance, whistleblowing channels from 50 employees, the voluntary gender equality certification, and the plastic and sugar taxes, currently due to start on 1 January 2027.

Open data The calendar is also available as JSON and plain text for systems and AI assistants: JSON · llms-full.txt

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