# Gruppo GM — Business Accelerator > Gruppo GM is a business accelerator combining an outsourced tender office and tender design, environmental and ESG consulting, certifications and management systems, subsidised finance and internationalization, with offices in Rome and Tokyo and a representative office in Shanghai acting as a bridge between Europe and China. - Web: https://www.gruppogm.eu/en/ - Email: segreteria@gruppogm.eu - Tel: +39 06 83 77 36 64 · +39 339 877 0967 · +81 343 605 000 (Tokyo) - Via Appia, 243 — 00183 Roma (RM) - Representative office — Shanghai: Shanghai, P.R. China — https://www.gruppogm.eu/en/china - 7F Fuji Building 40, 15-14 Sakuragaokacho, Shibuya-ku, Tokyo 150-0031 — https://www.gruppogm.eu/en/japan - Download the company profile: https://www.gruppogm.eu/assets/doc/gruppo-gm-company-profile-en.pdf ## Areas of expertise ### [Sustainability & Environmental Transition](https://www.gruppogm.eu/en/services/sustainability-esg) We guide companies and organisations through the entire sustainability journey: measuring environmental impacts, ESG reporting, environmental product declarations, life-cycle assessment and circular economy. We translate European regulation into a concrete operational plan, with the data and documentation needed to prove it to clients, authorities and auditors. - ESG reports and sustainability disclosures - Environmental product declarations and life-cycle assessment - Circular economy and by-product qualification procedures - Compliance with European environmental rules and technical files ### [Certifications & Management Systems](https://www.gruppogm.eu/en/services/certifications-management-systems) We build and maintain certified management systems: quality, environment, educational organisations, gender equality, plus the sector technical standards for cleaning, sanitisation and pest management services. We handle the whole journey — gap analysis, drafting of procedures and records, internal training, support during audits — through to certificate issue and its maintenance. - ISO certifications for quality, environment and organisation - Sector technical standards for services and operational processes - Gender equality certification - Attestations and qualifications for public works and tenders ### [Public Tenders & Tender Office](https://www.gruppogm.eu/en/tender-office) We design and draft bids for public procurement procedures in the sectors where we have hands-on experience: waste and environmental management, social care and residential services, sanitisation and disinfection, green space maintenance, construction and water-cycle engineering. From document analysis to the pricing model, through to administrative paperwork and coordination of consortia and joint ventures. - Tender document analysis and bidding strategy - Technical bid design and drafting - Administrative paperwork and qualification requirements - Pricing model and e-procurement portal management ### [Subsidised Finance & Grants](https://www.gruppogm.eu/en/services/subsidised-finance-grants) We constantly monitor grants and incentives available at regional, national and European level, and select the ones genuinely accessible to each company. We handle project design, the business plan, the application itself and final reporting, coordinating with the other areas to also fund certifications, sustainability investments and digitalization. - Scouting of regional, national and European grants and incentives - Eligibility analysis and application strategy - Business plan and technical-economic project design - Management, monitoring and reporting of the funding ### [Internationalization](https://www.gruppogm.eu/en/services/internationalization) We build the path into a new market: country analysis and selection, positioning against local competitors, partner and distributor scouting, product and documentation adaptation, corporate and commercial set-up. With our representative office in Shanghai we guide Chinese companies through European rules and into the European market, and Italian companies into China; with our Tokyo office we cover Japan. - Market analysis and entry strategy - Partner, distributor and agent scouting - Regulatory and documentation adaptation for the destination country - Operational set-up and commercial support ### [Business Organisation & Digitalization](https://www.gruppogm.eu/en/services/organisation-digitalization) We support companies through the moments when the organisation has to change: launching or restructuring the business, dealing with public bodies, redesigning internal processes and digitalizing document workflows. This is the foundation the other areas rest on: without orderly processes and traceable data you cannot pass an audit, win a tender or report on a grant. - Start-up, corporate restructuring and statutory compliance - Analysis and redesign of internal processes - Digitalization of document and administrative workflows - Automation of repetitive tasks and systems integration ### [Technology & Software Development](https://www.gruppogm.eu/en/services/technology-software) Software development is not standalone consulting: it is what makes everything else repeatable and provable. We design and build the tools our live projects need — deadline trackers for tenders and grants, document repositories for management systems, environmental data collection and validation, multilingual platforms and digital channels for foreign markets — with constant attention to efficiency: fewer resources consumed means lower costs and a smaller environmental footprint. - Deadline trackers and archives for tenders, requirements and grants - Dashboards for environmental data and ESG indicators - Document management for certified management systems - Multilingual websites, portals and e-commerce for foreign markets ## [China Desk — Representative office · Shanghai](https://www.gruppogm.eu/en/china) From our representative office in Shanghai we help Chinese companies comply with European regulation and do business in Italy, and Italian and European businesses operate in China. Sustainability and ESG, product compliance, legal and commercial matters: a single point of contact between Rome and Shanghai. We work in Italian, English and Chinese. ### China → Europe: Chinese companies exporting to, investing in or bidding for tenders in Europe The European market increasingly demands data and documentation: embedded emissions, compliant packaging, traceable supply chains, ESG information for customers. We help you understand which rules apply to your products and get ready ahead of the deadlines. - CBAM: calculation and verification of embedded emissions for steel, aluminium, cement and fertilisers - Packaging and Packaging Waste Regulation (PPWR), batteries, ecodesign and the Digital Product Passport - EUDR, forced labour and the due diligence required by European customers - ESG data and CSRD / VSME questionnaires for the value chain - Markings, ISO certifications and technical documentation - Company formation in Italy, partners, distributors and public tenders ### Europe → China: Italian and European businesses looking to sell, manufacture or source in China China has its own rules, standards and business practices. From Shanghai we support you from the choice of partners to product compliance, through to the ESG requests that increasingly come from Chinese customers too. - Market analysis, entry strategy and sales channels - Scouting and vetting of partners, suppliers and distributors - GB standards, mandatory CCC certification, labelling and packaging - Sustainability reporting required by Chinese stock exchanges and customers - Contracts, trademark protection and legal matters, with licensed partner professionals - Trade fairs, missions, B2B meetings and on-site support ### The services of the China desk - **Sustainability and ESG**: Environmental and social data collection, ESG reports, product and organisational carbon footprints, responses to questionnaires from European and Chinese customers. - **Carbon and CBAM**: Calculation of embedded emissions using the EU methodology, collection of installation data and preparation for verification, coordination with the European importer. - **Product compliance**: Packaging (PPWR), batteries, ecodesign, substances, CE marking and technical documentation for placing products on the European market; GB standards and CCC for China. - **Supply chain and due diligence**: EUDR geolocation and due diligence, forced labour checks, codes of conduct and supplier audits required by major customers. - **Legal and contractual advice**: Supply, distribution and agency agreements, trademark protection, choice of corporate structure, in collaboration with partner lawyers and accountants in Italy and China. - **Commercial consulting**: Market analysis, positioning, scouting and selection of partners, distributors and suppliers, support through negotiations and first sales. - **Companies and investment in Italy**: Company formation, registered office, tax and employment compliance, authorisations and foreign investment screening in strategic sectors. - **Tenders, certifications and incentives**: Participation in public tenders in Italy, ISO and sector certifications, subsidised finance for productive investment and the green transition. ### Working between Europe and China **What does Gruppo GM's representative office in Shanghai do?** It is Gruppo GM's direct point of contact in China. It supports Chinese companies that export to, invest in or bid for tenders in Europe, helping them comply with European rules on carbon, packaging, products, supply chains and ESG, as well as Italian and European businesses looking to operate in China. It coordinates with our Rome office on Italian and European matters. **Do you help Chinese manufacturers with CBAM?** Yes. Since 2026 CBAM has been in its definitive phase: European importers of steel, aluminium, cement, fertilisers and hydrogen are asking producers for verified data on embedded emissions. We help Chinese installations calculate them using the EU methodology, prepare the documentation for verification and coordinate with the importer, ahead of the first annual declaration due on 31 August 2027. **Which European rules do Chinese companies exporting to the EU need to know?** It depends on the product. The main ones are CBAM for carbon-intensive materials, the Packaging and Packaging Waste Regulation (PPWR, applicable from 12 August 2026), the Batteries Regulation, ecodesign with the Digital Product Passport, the EUDR for wood, rubber, soya and other commodities, the ban on products made with forced labour (from December 2027) and the ESG data requests of customers subject to the CSRD and CSDDD. **Can a Chinese company take part in public tenders in Italy?** Yes, provided it meets the requirements of the Italian Public Contracts Code. However, account must be taken of the EU Foreign Subsidies Regulation (FSR), which requires foreign financial contributions to be notified in tenders worth €250 million or more, and of the International Procurement Instrument (IPI), already applied to medical devices. Our tender office handles the preparation of the bid and supporting documentation. **Which Chinese ESG rules affect Italian businesses working in China?** In 2024 the Shanghai, Shenzhen and Beijing stock exchanges published sustainability reporting guidelines, mandatory for major listed companies, with the first reports covering financial year 2025; the Ministry of Finance is building national disclosure standards, and the national carbon market has been extended to steel, cement and aluminium. For Italian suppliers this means receiving more and more ESG data requests from Chinese customers too. **Which languages do you work in, and how do we get started?** We work in Italian, English and Chinese. We start with a free initial meeting, in Shanghai, in Rome or by video call, in which we identify the applicable rules, deadlines and priorities. You can reach us by email or WhatsApp. ### EU–China practical guides #### [CBAM for Chinese manufacturers and exporters: what you need from 2026](https://www.gruppogm.eu/en/china/guides/cbam-chinese-exporters) **The short answer:** Since 1 January 2026 CBAM has been in its definitive phase: anyone importing more than 50 tonnes a year of iron and steel, aluminium, cement, fertilisers or hydrogen into the EU must be an authorised CBAM declarant and buy certificates matching the embedded emissions of the goods. The cost depends on data from the production installation in China: without verified data, default values apply, and these are usually more punitive. For a Chinese manufacturer, supplying accurate data has become a competitive advantage. **Who this guide is for:** Steelworks, foundries and producers of aluminium, cement, fertilisers and hydrogen in China, plus traders and exporters selling these materials, and the downstream products listed in Annex I (such as screws, bolts and certain semi-finished goods), to European customers. **Who pays and who supplies the data.** The legal obligation falls on the EU importer, who submits the annual declaration and surrenders the certificates. But embedded emissions are calculated at the installation that produced the goods: it is the Chinese manufacturer that has to collect the data and pass it on, usually using the communication template provided by the European Commission. Installations outside the EU can also register in the CBAM Registry, so that they can share verified data with several importers. **How embedded emissions are calculated.** The method is the EU one: it covers direct process emissions, emissions from precursors (for example clinker in cement or pig iron in steel) and, for cement and fertilisers, indirect emissions from electricity as well. A product carbon footprint calculated under other standards is not enough: system boundaries, allocation rules and monitoring data must follow the CBAM methodology, and in the definitive phase the data must be verified by an accredited verifier. **Carbon price paid in China.** The regulation allows the importer to reduce the number of certificates to surrender by the carbon price actually paid in the country of origin. China's national emissions trading scheme covers the power sector and, since 2025, steel, cement and aluminium too: properly documenting the costs incurred in China can therefore lower the bill for the European customer. **Deadlines.** Definitive phase from 1 January 2026; sale of CBAM certificates from 1 February 2027; first annual declaration, covering 2026 imports, by 31 August 2027. Free allowances under the EU ETS are being phased out gradually until 2034, so the financial weight of CBAM will grow every year. **Step by step:** 1. Identify the CN codes of the products you sell in the EU that fall within CBAM 2. Map installations, production processes and purchased precursors 3. Set up a monitoring plan in line with the EU methodology 4. Collect precursor data from your own suppliers 5. Have the data verified by an accredited verifier 6. Send the emissions communications to importers and agree data, timing and costs in your contracts **Mistakes to avoid:** - Relying on default values: they cost your customer more and weaken your offer - Using a carbon footprint calculation that does not follow the CBAM methodology - Delivering data after the importer's deadlines **Does CBAM also cover finished products?** At present it mainly covers basic materials and some downstream products listed in Annex I, such as steel screws and bolts. The Commission has proposed extending it to further downstream products to prevent circumvention, so it is worth checking the list of codes regularly. **Who has to buy CBAM certificates?** The authorised EU importer (CBAM declarant). The Chinese manufacturer does not buy certificates, but its data determines how many are needed and therefore the final cost of the goods. **What happens if I do not provide the data?** The importer has to use the default values set by the Commission, which are generally higher than the actual emissions of an efficient installation. The extra cost ends up in the commercial negotiation. **Can the price paid in the Chinese carbon market be deducted?** Yes, provided it has actually been paid and is documented according to EU rules. The deduction reduces the number of certificates the importer has to surrender. #### [How a Chinese company can set up a company in Italy: practical guide](https://www.gruppogm.eu/en/china/guides/set-up-company-in-italy-chinese-business) **The short answer:** The most common form is the S.r.l. (Italian limited liability company), incorporated by notarial deed and entered in the Business Register; alternatively, the Chinese company can open an Italian branch or a representative office with no commercial activity. Shareholders and directors need an Italian tax code (codice fiscale), and the company needs a registered office in Italy, a certified email (PEC) address and a VAT number. China joined the Apostille Convention in November 2023, which simplifies the legalisation of corporate documents. **Who this guide is for:** Chinese companies that want a permanent presence in Italy to sell, distribute, manufacture or bid in public tenders, and investors looking to acquire Italian businesses. **The options available.** An S.r.l. can be incorporated with minimum share capital of €1, although in practice a larger amount is contributed to build credibility with banks and customers; an S.p.A. (joint-stock company) requires at least €50,000. A branch (sede secondaria) has no separate legal personality: the Chinese company is directly liable. A representative office may only carry out promotional and liaison activities, not sell. **Documents and steps.** You need the parent company's corporate documents (articles of association, certificate of registration, board resolution), apostilled in China and given a sworn translation into Italian, identity documents for shareholders and directors and their Italian tax codes, which can also be obtained through the consulates. Then come the deed before a notary, entry in the Business Register, assignment of the VAT number, the PEC address, opening a bank account and, if there are employees, registration with INPS (social security) and INAIL (workplace insurance). **Golden power and strategic sectors.** Foreign investment in sectors such as defence, energy, transport, communications and 5G, healthcare, agri-food and finance may require prior notification to the Presidency of the Council of Ministers under the golden power rules (Decree-Law 21/2012). Assessing this at the outset avoids blocks or conditions once the deal is already under way. **Tax, staff and permits.** Italian companies pay IRES (corporate income tax) at 24% and IRAP (regional tax on productive activities), generally at 3.9%, plus VAT. Staff are hired under the national collective agreement for the sector. Managers and staff transferred from China can obtain dedicated work permits outside the ordinary quotas, which need to be planned in good time. **Step by step:** 1. Choose the form (S.r.l., branch, representative office) according to the planned activities 2. Check whether the sector falls under golden power 3. Prepare and apostille the parent company's documents in China, with a sworn translation 4. Obtain Italian tax codes for shareholders and directors 5. Incorporate the company before a notary and complete the Business Register entry, VAT number and PEC 6. Open the bank account and set up accounting, staff and work permits **Mistakes to avoid:** - Underestimating the time needed for tax codes, bank accounts and translations - Opening a representative office when the goal is to sell - Discovering golden power only after the negotiations are closed **What is the minimum share capital for an S.r.l. in Italy?** €1 by law. To access credit and win contracts with major customers, a higher amount is usually contributed, often at least €10,000. **Can the director live in China?** Yes, the director can be non-resident, but needs an Italian tax code and a digital signature for many formalities. A local attorney-in-fact or director is often appointed alongside. **How long does it take?** With the documents ready, incorporation usually takes a few weeks; the longest lead times are typically for the Apostille, translations and opening the bank account. **Is a representative office enough to sell in Italy?** No: a representative office can only carry out promotion and liaison. To issue invoices you need a branch or a company. #### [PPWR packaging regulation: what Chinese exporters need to do](https://www.gruppogm.eu/en/china/guides/ppwr-packaging-chinese-exporters) **The short answer:** From 12 August 2026 all packaging placed on the EU market, including packaging around products made in China, must comply with the Packaging and Packaging Waste Regulation (EU) 2025/40: limits on PFAS in food-contact packaging and on heavy metals, an EU declaration of conformity and technical documentation. Harmonised labels follow from 2028 and, from 2030, mandatory recyclability, minimum recycled content and a maximum empty space ratio of 50%. The obligations fall on manufacturers, importers and distributors, but the data is requested from Chinese suppliers. **Who this guide is for:** Chinese packaging manufacturers, producers of goods packed in China and sold in the EU, and online sellers and platforms shipping to European consumers. **Who has obligations.** The manufacturer is whoever produces the packaging or has it designed and produced under its own name; the importer is whoever first places it on the EU market; distributors and fulfilment service providers must check compliance. Anyone selling directly to European consumers from outside the EU must appoint an authorised representative for extended producer responsibility in each Member State where they sell. **What changes from 12 August 2026.** Food-contact packaging must not exceed the limits set for PFAS; for all packaging, the combined concentration of lead, cadmium, mercury and hexavalent chromium must stay below 100 mg/kg. Every packaging item needs an EU declaration of conformity and technical documentation demonstrating compliance with the requirements, to be kept and provided to the authorities on request. **The next milestones: 2028 and 2030.** From August 2028 the harmonised material label for waste sorting comes in. From 2030 all packaging must be recyclable (grades A, B or C), plastic packaging must contain a minimum share of recycled content, e-commerce, grouped and transport packaging may not have more than 50% empty space, and certain single-use formats are banned. **E-commerce and distance sales.** Anyone shipping directly to European consumers must be entered in the producer registers of the destination countries and join the extended producer responsibility schemes; online platforms must check this. Without registration, products can be removed from the marketplace. **Step by step:** 1. Inventory packaging by product: materials, weights, suppliers, destination markets 2. Collect PFAS and heavy metal declarations from suppliers 3. Prepare the EU declaration of conformity and technical documentation 4. Register with EPR schemes and appoint the authorised representative where required 5. Plan for the 2028 harmonised labels 6. Redesign packaging for recyclability, recycled content and empty space by 2030 **Mistakes to avoid:** - Assuming the regulation only applies to European manufacturers - Forgetting secondary and transport packaging - Putting off redesign until 2029, when suppliers and recycled materials will be scarcer **Does the PPWR apply to packaging made in China?** Yes: what matters is where the packaging is placed on the market, not where it is made. All packaging sold in the EU must comply. **Do I need a representative in Europe?** Anyone making distance sales to European consumers from outside the EU must appoint an authorised representative for extended producer responsibility in each Member State where they sell. **Are corrugated cardboard boxes covered?** Yes, the regulation covers all materials and all levels of packaging: primary, secondary and transport. **When do the new labels become mandatory?** The harmonised material labels apply from August 2028, or 24 months after the Commission's implementing act if that is later. #### [EUDR, forced labour and batteries: EU rules for the Chinese supply chain](https://www.gruppogm.eu/en/china/guides/eudr-forced-labour-batteries-chinese-suppliers) **The short answer:** Three EU rules require companies to prove what happens upstream in the supply chain. The Deforestation Regulation (EUDR), applying from 30 December 2026 to large and medium-sized companies, requires geolocation of commodities such as wood, rubber and soy; the Forced Labour Regulation bans products made with forced labour from 14 December 2027, whatever their origin; the Batteries Regulation introduces the digital battery passport from February 2027 and raw-material due diligence from August 2027. European customers will pass these requirements on to their Chinese suppliers. **Who this guide is for:** Chinese suppliers of furniture, paper, wood, tyres and rubber goods and soy-based products; manufacturers of batteries and battery-powered equipment; and any exporter whose European customers are subject to due diligence. **EUDR: wood, rubber and other commodities.** For cattle, cocoa, coffee, oil palm, rubber, soy and wood, and for the listed derived products (furniture, paper, tyres and others), whoever places the product on the EU market must prove that it is not linked to deforestation after 31 December 2020 and that it complies with the laws of the country of production, with the coordinates of the plots of land. China is a major processor of imported wood and rubber, so traceability data going right back to the origin is needed. **The ban on products made with forced labour.** The regulation applies to all products and all operators, with no size thresholds. Authorities can investigate on the basis of information received and a database of risks, and can ban, withdraw or order the disposal of goods. For suppliers, this means being able to document working conditions and the origin of components. **Batteries Regulation.** Industrial, electric vehicle and light means of transport (LMT) batteries will need a digital battery passport from 18 February 2027; due diligence on cobalt, lithium, nickel and natural graphite applies from 18 August 2027; the carbon footprint follows and, from 2031, minimum recycled content. For China's battery industry this is the most significant change on the European market. **Step by step:** 1. Map the products sold in the EU that fall under the three regulations 2. Trace the supply chain back to the raw materials, with suppliers and countries of origin 3. Collect geolocation data and proof of legality for EUDR commodities 4. Adopt a due diligence policy and supplier audits 5. Prepare the data for the battery passport and the carbon footprint 6. Agree data formats and delivery times with European customers **Mistakes to avoid:** - Assuming a generic sustainability certificate is enough - Stopping at the direct supplier without tracing back to the raw materials - Waiting for the customer's formal request before starting **Does the EUDR apply to Chinese companies?** The obligations fall on whoever places the product on the EU market, but without the Chinese supplier's data the importer cannot complete the due diligence statement. In practice, the request reaches the whole supply chain. **When does the ban on forced labour products apply?** From 14 December 2027, for all products placed on or exported from the EU market, including online sales. **What is the battery passport?** A digital record, accessible via a QR code, with information on composition, performance, origin of materials and carbon footprint. It is mandatory from 18 February 2027 for industrial batteries above 2 kWh, electric vehicle batteries and batteries for light means of transport. **Are Chinese SMEs exempt?** No. The Forced Labour Regulation has no thresholds; the EUDR only gives micro and small companies placing products on the EU market more time. #### [Public tenders in Italy for Chinese companies: requirements, FSR and IPI](https://www.gruppogm.eu/en/china/guides/public-tenders-italy-chinese-companies) **The short answer:** A Chinese company can take part in public tenders in Italy, but with some caveats. China is not a party to the WTO Government Procurement Agreement and, according to the Court of Justice of the EU (Kolin judgment, October 2024), operators from countries with no procurement agreement with the EU cannot rely on the EU directives: participation therefore depends on the choices of the contracting authority. In contracts worth €250 million or more, foreign financial contributions must be notified under the Foreign Subsidies Regulation (FSR), and International Procurement Instrument (IPI) measures apply to medical devices. **Who this guide is for:** Chinese companies in construction, plant engineering, energy, transport, technology and medical devices, bidding alone or in a temporary consortium with Italian companies. **The framework: Public Contracts Code and third-country access.** Italian tenders are governed by the Public Contracts Code (Legislative Decree 36/2023). For operators from countries with no procurement agreement with the EU, such as China, the contracting authority can decide whether to admit them and on what terms. The most solid route is often to bid through a company incorporated in Italy or in a temporary consortium (RTI) with Italian companies. **Foreign subsidies (FSR).** If the estimated contract value is €250 million or more and the operator has received financial contributions of at least €4 million per country from non-EU states in the last three years, a notification must be submitted to the European Commission; otherwise, a declaration. The award is suspended during the review. **The International Procurement Instrument (IPI).** Since 2025 the EU has applied the first IPI measure: in tenders for medical devices worth more than €5 million, Chinese operators are excluded and bids may contain only a limited share of components of Chinese origin. Further measures may cover new sectors. **Requirements and the bid.** Public works above €150,000 require SOA certification; for services and supplies, turnover, similar past contracts and certifications such as ISO 9001, 14001 and 45001 count. All documentation must be translated and uploaded to the e-procurement platforms; the technical bid, which accounts for at least 70% of the score in tenders awarded on the most economically advantageous tender basis, must be built around the tender criteria and the minimum environmental criteria (CAM). **Step by step:** 1. Check whether the contracting authority admits third-country operators and on what terms 2. Consider bidding through an Italian company or a temporary consortium 3. Check the applicable FSR thresholds and IPI measures 4. Obtain the required qualifications and certifications (SOA, ISO) 5. Prepare the translated administrative documents and the technical bid 6. Handle the upload, clarification requests and post-award verification of requirements **Mistakes to avoid:** - Assuming you have the same right to bid as an EU operator - Discovering the FSR notification requirement after the bid has been submitted - Translating a standard technical bid instead of building it around the tender criteria **Can a Chinese company bid in a public tender in Italy?** Yes, but the contracting authority can restrict its access, because China has no procurement agreement with the EU. Bidding through an Italian company or in a temporary consortium with Italian companies is often the safest option. **When is an FSR notification required?** In contracts with an estimated value of €250 million or more, if the operator and its group have received at least €4 million in contributions from a non-EU state in the previous three years. **What does the IPI measure on medical devices provide for?** It excludes Chinese operators from tenders for medical devices worth more than €5 million and limits the share of components of Chinese origin in bids from other operators. **What is SOA certification?** It is the mandatory qualification for carrying out public works worth more than €150,000 in Italy, issued by authorised bodies by category and value class. #### [How to enter the Chinese market: a guide for Italian companies](https://www.gruppogm.eu/en/china/guides/entering-the-chinese-market) **The short answer:** Before selling in China, register your trademark, including in Chinese characters, because protection is based on the first-to-file principle. Then choose how to enter: a distributor, cross-border e-commerce, a wholly foreign-owned enterprise (WFOE) or a joint venture. Many products require mandatory CCC certification or compliance with national GB standards, Chinese-language labels and, for food, registration of the overseas manufacturer with China's customs authority (GACC). **Who this guide is for:** Italian companies in food and agri-food, wine, fashion and design, machinery, components, cosmetics and environmental technologies that want to sell, produce or source in China. **Market entry options.** A local distributor reduces investment and risk but limits control over pricing and brand; cross-border e-commerce lets you test the market under simplified rules for certain categories; a wholly foreign-owned enterprise (WFOE) can invoice, hire and import directly; a representative office is for promotion and finding partners, and cannot sell. **Trademark first.** In China a trademark belongs to whoever files it first. Filing it before attending trade fairs or meeting potential partners, in the right classes and in a Chinese-character version too, avoids having to buy it back or finding it registered by someone else. **Product compliance.** Household appliances, electrical components, toys and other listed products require CCC certification; many others must comply with national GB standards. Pre-packaged food must carry a Chinese label in line with standard GB 7718 and, since 2022, overseas food manufacturers must register with the GACC; cosmetics require registration or notification with the competent authority. **ESG requests from Chinese customers.** From 2026 China's leading listed companies publish mandatory sustainability reports under stock exchange guidelines: European suppliers are therefore receiving more requests for data on emissions, safety and the supply chain, just as they already do from European customers. **Step by step:** 1. Assess demand and choose priority cities and channels 2. File your trademark in China, including in Chinese characters 3. Check CCC, GB standards, labelling and registrations for your product 4. Select and vet partners and distributors 5. Define contracts, pricing, payment terms and intellectual property protection 6. Launch sales through trade fairs, B2B meetings and local digital channels **Mistakes to avoid:** - Showing your product in China before registering the trademark - Choosing a distributor without checking its financial standing and portfolio - Underestimating certification and registration lead times **Do I need a company in China to sell there?** No, you can sell through a distributor or via cross-border e-commerce. A local company becomes useful when you need direct invoicing, staff and your own import operations. **How do I protect my trademark in China?** By filing it with the China National Intellectual Property Administration (CNIPA) before entering the market, in the relevant classes and in a Chinese-character version too, because the first-to-file principle applies. **What is CCC certification?** China Compulsory Certification (CCC) is mandatory for products listed in an official catalogue, mainly electrical and electronic goods, automotive products and toys. Without CCC these products cannot be imported or sold. **Does an Italian food manufacturer need to register in China?** Yes: since 1 January 2022 overseas manufacturers of food exported to China must be registered with the General Administration of Customs of China (GACC), either directly or through the authorities of the country of origin, depending on the product category. ## [Japan Desk — Office · Tokyo](https://www.gruppogm.eu/en/japan) From our office in Shibuya, Tokyo, we help Japanese companies comply with European regulation and do business in Italy, and Italian businesses enter the Japanese market by making the most of the EU–Japan Economic Partnership Agreement. Sustainability and ESG, product compliance, legal and commercial matters. We work in Italian, English and Japanese. ### Japan → Europe: Japanese companies exporting to, investing in or with subsidiaries in Europe Japanese groups active in Europe face a fast-changing regulatory framework: sustainability reporting, carbon at the border, packaging, batteries, supply-chain due diligence. We help you understand what applies to your companies and your products, and prepare in good time. - CSRD for European subsidiaries and, from 2028, for non-EU groups with more than €450 million of EU turnover - CBAM: embedded emissions of exported steel, aluminium and other materials - Packaging Regulation (PPWR), Batteries Regulation, ecodesign and the digital product passport - Supply-chain due diligence (CSDDD) and ESG requests from European customers - CE marking, ISO certifications and technical documentation - Companies, partners and distributors in Italy, public tenders and incentives ### Europe → Japan: Italian businesses that want to sell, manufacture or invest in Japan Japan is a demanding and loyal market, with its own standards and buying habits. Thanks to the EU–Japan agreement most tariffs have been eliminated: we support you from choosing partners to product compliance, right through to the ESG requests of Japanese customers. - Market analysis, positioning and market-entry strategy - Finding and vetting importers, distributors and partners - Rules of origin and preferential tariffs under the EU–Japan agreement (EPA) - JIS standards, PSE mark for electrical products, labelling and packaging - ESG data required by the SSBJ standards and by Japanese customers - Contracts, trademark protection, trade fairs and B2B meetings ### The services of the Japan desk - **Sustainability and ESG**: ESG reports, carbon footprint, data for CSRD and the SSBJ standards, answers to questionnaires from European and Japanese customers. - **Carbon, CBAM and GX**: Embedded emissions under the EU methodology, coordination with European importers and comparison with the Japanese GX-ETS. - **Product compliance**: Packaging, batteries, ecodesign and CE marking for Europe; JIS standards, PSE and labelling for Japan. - **EU–Japan agreement**: Rules of origin, statement on origin and preferential tariffs to make the most of the Economic Partnership Agreement. - **Legal and contractual advice**: Distribution, agency and supply contracts, trademark protection and corporate form, with partner lawyers and accountants. - **Commercial consulting**: Market analysis, partner search and selection, support in negotiations, at trade fairs and with first sales. - **Companies and investment in Italy**: Company incorporation, registered office, tax and employment obligations, foreign investment screening in strategic sectors. - **Tenders, certifications and incentives**: Participation in public tenders in Italy, ISO and sector certifications, subsidised finance for investment. ### Working between Europe and Japan **What does Gruppo GM's Tokyo office do?** It is Gruppo GM's operational office in Japan, in Shibuya. It supports Japanese companies operating or investing in Europe, helping them with European rules on sustainability, carbon, products and supply chains, as well as Italian businesses that want to enter the Japanese market. It works in coordination with our Rome headquarters. **What benefits does the EU–Japan Economic Partnership Agreement offer Italian exporters?** In force since 1 February 2019, the agreement has eliminated most tariffs on European products, including many agri-food products and wine, protects geographical indications and reduces technical barriers. To obtain the preferential tariff, you must meet the rules of origin and prepare a statement on origin. **Do Japanese groups have to apply the CSRD in Europe?** Yes, in two ways. European subsidiaries that exceed the Omnibus package thresholds (more than 1,000 employees and €450 million in turnover) report from financial year 2027; from 2028 the obligation also covers non-EU groups with more than €450 million of EU turnover. We help set up data and processes consistently with the Japanese SSBJ standards. **What are the SSBJ standards and why do they matter to Italian suppliers?** They are the sustainability standards of the Sustainability Standards Board of Japan, published in March 2025 and aligned with ISSB. They will become mandatory on a phased basis for large companies listed on the Prime Market, starting with financial years ending in March 2027. For European suppliers, this means receiving requests for emissions and supply-chain data from Japanese customers. **Does CBAM affect Japanese exporters?** Yes: anyone exporting steel, aluminium, cement, fertilisers or hydrogen to Europe must provide European importers with verified data on embedded emissions. Japan is introducing its own carbon pricing through the GX-ETS, mandatory for large emitters from 2026: we help coordinate the two monitoring systems. **Which languages do you work in, and how do we get started?** We work in Italian, English and Japanese. It all starts with a free first meeting, in Tokyo, in Rome or by video call, where we define rules, deadlines and priorities. You can write to us by email or WhatsApp. ## ESG Regulations — The complete map, from 2021 to 2040 Content updated as of 25 Oct 2026, for information purposes only. Several regulations are being simplified (Omnibus packages) or are awaiting delegated and implementing acts: dates marked as "estimate" may change. Before making decisions, check with us how they apply to your business. - Open data (JSON): https://www.gruppogm.eu/en/esg-regulations.json ### The questions we are asked most often **What are the main ESG deadlines in 2026 and 2027?** 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 31 August and, from financial year 2027, CSRD with simplified ESRS for companies with more than 1,000 employees and €450 million turnover. **After the Omnibus package, who has to report under the CSRD?** 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. **When does the PPWR apply and what changes for companies?** 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. **Does CBAM apply to SMEs?** 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. **When does the EU Deforestation Regulation (EUDR) apply?** 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. **Which environmental and ESG obligations apply only in Italy?** 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. ### Reporting and sustainable finance #### [CSRD — Corporate Sustainability Reporting Directive](https://www.gruppogm.eu/en/esg-regulations/csrd) - Legal reference: Directive (EU) 2022/2464 · Legislative Decree 125/2024 · Directive (EU) 2025/794 "Stop-the-clock" and Omnibus I - Status: Phased application - Official text: EUR-Lex · Directive (EU) 2022/2464 — https://eur-lex.europa.eu/eli/dir/2022/2464/oj/eng - Official text: Normattiva · D.Lgs. 125/2024 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2024;125 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. **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. **Deadlines:** - 2023-01-05 — Entry into force of the CSRD - 2024-01-01 — First wave: entities already subject to the NFRD report from financial year 2024 (reports published in 2025) - 2024-09-25 — Legislative Decree 125/2024 transposing the CSRD in Italy enters into force - 2025-04-17 — "Stop-the-clock" Directive: two-year postponement for the second and third waves - 2026-02-01 (estimate) — Final adoption of the Omnibus I package: new thresholds of 1,000 employees and €450 million - 2027-01-01 — Financial year 2027: obligation for large companies within the new scope (first report in 2028) - 2027-03-01 (estimate) — Indicative deadline for national transposition of the Omnibus amendments - 2028-01-01 — Financial year 2028: obligation for non-EU groups with more than €450 million in EU revenue **What companies need 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 #### [ESRS — European Sustainability Reporting Standards](https://www.gruppogm.eu/en/esg-regulations/esrs) - Legal reference: Commission Delegated Regulation (EU) 2023/2772 and subsequent EFRAG revisions - Status: Phased application - Official text: EUR-Lex · Delegated Regulation (EU) 2023/2772 — https://eur-lex.europa.eu/eli/reg_del/2023/2772/oj/eng 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. **Who it applies to:** All companies subject to the CSRD; in practice, also suppliers that are asked for environmental and social data. **Deadlines:** - 2023-12-22 — Publication of the first set of ESRS in the Official Journal - 2025-07-11 — "Quick fix": the Commission extends the phase-in reliefs for first-wave companies - 2025-12-03 — EFRAG delivers the simplified ESRS to the Commission - 2026-06-01 (estimate) — Commission delegated act on the revised ESRS (expected) - 2027-01-01 — Application of the simplified ESRS from financial year 2027 **What companies need 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 #### [VSME — Voluntary Sustainability Reporting Standard for SMEs](https://www.gruppogm.eu/en/esg-regulations/vsme) - Legal reference: Commission Recommendation of 30 July 2025 · EFRAG VSME standard - Status: In force 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. **Who it applies to:** SMEs and companies with up to 1,000 employees that want (or need, for their customers) to disclose ESG data. **Deadlines:** - 2024-12-17 — EFRAG publishes the VSME standard - 2025-07-30 — The Commission adopts the Recommendation on the VSME - 2027-01-01 — The VSME becomes the information cap for the value chain of CSRD companies **What companies need 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 #### [EU Taxonomy for sustainable activities](https://www.gruppogm.eu/en/esg-regulations/eu-taxonomy) - Legal reference: Regulation (EU) 2020/852 · Climate, Environmental and 2025 Simplification Delegated Acts - Status: In force - Official text: EUR-Lex · Regulation (EU) 2020/852 — https://eur-lex.europa.eu/eli/reg/2020/852/oj/eng 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. **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. **Deadlines:** - 2020-07-12 — Entry into force of the Taxonomy Regulation - 2022-01-01 — Application for the climate change mitigation and adaptation objectives - 2024-01-01 — Extension to the other four environmental objectives (water, circular economy, pollution, biodiversity) - 2026-01-01 — Simplification applies: 10% materiality threshold and reduced templates **What companies need 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 #### [SFDR — Sustainable Finance Disclosure Regulation](https://www.gruppogm.eu/en/esg-regulations/sfdr) - Legal reference: Regulation (EU) 2019/2088 · "SFDR 2.0" review proposal of 20 November 2025 - Status: Under negotiation - Official text: EUR-Lex · Regulation (EU) 2019/2088 — https://eur-lex.europa.eu/eli/reg/2019/2088/oj/eng 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. **Who it applies to:** Financial market participants; indirectly, companies that receive ESG data requests from funds and banks. **Deadlines:** - 2021-03-10 — Application of the Level 1 obligations - 2023-01-01 — Application of the regulatory technical standards (RTS) - 2025-11-20 — The Commission presents the "SFDR 2.0" proposal - 2028-01-01 (estimate) — Possible application of the new rules, following negotiations **What companies need to do:** - Prepare for ESG questionnaires from investors and lenders - Make the principal adverse impact (PAI) indicators available #### [ESG Rating Activities Regulation](https://www.gruppogm.eu/en/esg-regulations/esg-ratings-regulation) - Legal reference: Regulation (EU) 2024/3005 - Status: In force - Official text: EUR-Lex · Regulation (EU) 2024/3005 — https://eur-lex.europa.eu/eli/reg/2024/3005/oj/eng 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. **Who it applies to:** ESG rating providers; for rated companies, it means clearer methodologies and the ability to report errors. **Deadlines:** - 2025-01-01 — Entry into force of the regulation - 2026-07-02 — Application: rating providers must be authorised by ESMA **What companies need to do:** - Review your ratings and the methodologies behind them - Keep ESG data public, consistent and up to date #### [European Green Bond Standard (EuGB)](https://www.gruppogm.eu/en/esg-regulations/european-green-bond-standard) - Legal reference: Regulation (EU) 2023/2631 - Status: In force - Official text: EUR-Lex · Regulation (EU) 2023/2631 — https://eur-lex.europa.eu/eli/reg/2023/2631/oj/eng 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. **Who it applies to:** Companies and entities that issue bonds or finance green projects. **Deadlines:** - 2023-12-20 — Entry into force - 2024-12-21 — Application of the EuGB standard **What companies need to do:** - Consider the EuGB label for financing transition projects ### Packaging and circular economy #### [PPWR — Packaging and Packaging Waste Regulation](https://www.gruppogm.eu/en/esg-regulations/ppwr) - Legal reference: Regulation (EU) 2025/40 on packaging and packaging waste, repealing Directive 94/62/EC - Status: Phased application - Official text: EUR-Lex · Regulation (EU) 2025/40 — https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng 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. **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. **Deadlines:** - 2025-02-11 — Entry into force of the regulation - 2026-08-12 — General application: EU declaration of conformity, PFAS limits in food-contact packaging, heavy metals below 100 mg/kg, new obligations for producers - 2028-02-12 — HORECA takeaway: obligation to offer customers a reusable alternative - 2028-08-12 — Harmonised EU material label for separate collection - 2029-01-01 — Mandatory deposit return scheme for single-use plastic bottles and cans up to 3 litres - 2030-01-01 — 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% - 2035-01-01 — Recyclability "at scale" and a 10% reduction in packaging waste - 2038-01-01 — Recyclability grade C is also banned from the market - 2040-01-01 — Recycled content of 50–65% in plastic, extended reuse, waste −15% **What companies need 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 #### [Single-Use Plastics Directive (SUP)](https://www.gruppogm.eu/en/esg-regulations/single-use-plastics-directive) - Legal reference: Directive (EU) 2019/904 · Legislative Decree 196/2021 - Status: Phased application - Official text: EUR-Lex · Directive (EU) 2019/904 — https://eur-lex.europa.eu/eli/dir/2019/904/oj/eng - Official text: Normattiva · D.Lgs. 196/2021 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2021;196 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. **Who it applies to:** Producers and distributors of beverages, food containers, tobacco products, wet wipes, balloons and fishing gear. **Deadlines:** - 2021-07-03 — Market restrictions and marking requirements - 2024-07-03 — Tethered caps mandatory on bottles up to 3 litres - 2025-01-01 — PET bottles with at least 25% recycled plastic - 2026-01-01 — Separate collection target of 77% of bottles (placed on the market in 2025) - 2030-01-01 — All beverage bottles with at least 30% recycled plastic **What companies need to do:** - Check banned products and the alternatives permitted in Italy - Check bottle markings and recycled content #### [Targeted revision of the Waste Framework Directive: textiles and food waste](https://www.gruppogm.eu/en/esg-regulations/waste-framework-directive-textiles-food) - Legal reference: Directive (EU) 2025/1892, amending Directive 2008/98/EC - Status: Forthcoming - Official text: EUR-Lex · Directive (EU) 2025/1892 — https://eur-lex.europa.eu/eli/dir/2025/1892/oj/eng Introduces mandatory extended producer responsibility for textiles, clothing and footwear in all Member States, together with binding food waste reduction targets by 2030. **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. **Deadlines:** - 2025-10-16 — Entry into force of the directive - 2027-06-17 (estimate) — Transposition deadline for Member States - 2028-04-17 (estimate) — Textile EPR schemes operational in all Member States - 2030-12-31 — Food waste: −10% in processing and manufacturing, −30% per capita in retail, food service and households **What companies need to do:** - Prepare to register with textile EPR schemes and for the related eco-modulation - Measure food waste and define a reduction plan ### Products, ecodesign and consumers #### [ESPR — Ecodesign for Sustainable Products Regulation and Digital Product Passport](https://www.gruppogm.eu/en/esg-regulations/espr-ecodesign-digital-product-passport) - Legal reference: Regulation (EU) 2024/1781 - Status: Phased application - Official text: EUR-Lex · Regulation (EU) 2024/1781 — https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng 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. **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. **Deadlines:** - 2024-07-18 — Entry into force of the regulation - 2025-04-16 — ESPR 2025–2030 working plan with the priority product groups - 2025-07-19 — Large companies begin disclosing discarded unsold products - 2026-07-19 — Ban on destroying unsold clothing and footwear (large companies); EU Digital Product Passport registry - 2027-06-01 (estimate) — First delegated acts with requirements for textiles and steel (expected) - 2030-07-19 — The destruction ban is extended to medium-sized companies **What companies need 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 #### [Batteries Regulation](https://www.gruppogm.eu/en/esg-regulations/batteries-regulation) - Legal reference: Regulation (EU) 2023/1542 · due diligence postponement Regulation (EU) 2025/1561 - Status: Phased application - Official text: EUR-Lex · Regulation (EU) 2023/1542 — https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng 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. **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. **Deadlines:** - 2024-02-18 — General application of the regulation - 2026-08-18 — New labelling requirements (capacity, composition, lifetime) - 2027-02-18 — Battery passport for industrial, EV and LMT batteries; removable and replaceable portable batteries; QR code - 2027-08-18 — Due diligence obligations on raw materials (postponed by two years) - 2031-08-18 — Minimum recycled content: 16% cobalt, 6% lithium, 6% nickel, 85% lead **What companies need 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 #### [Empowering Consumers for the Green Transition Directive: an end to greenwashing](https://www.gruppogm.eu/en/esg-regulations/empowering-consumers-directive-greenwashing) - Legal reference: Directive (EU) 2024/825, amending the Unfair Commercial Practices Directives - Status: In force - Official text: EUR-Lex · Directive (EU) 2024/825 — https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng 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. **Who it applies to:** All companies that communicate with consumers: labels, packaging, websites, advertising, social media. **Deadlines:** - 2024-03-26 — Entry into force of the directive - 2026-03-27 — Deadline for transposition into national law - 2026-09-27 — The new bans apply throughout the EU **What companies need 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 #### [Proposed Green Claims Directive](https://www.gruppogm.eu/en/esg-regulations/green-claims) - Legal reference: Proposal COM(2023) 166 - Status: Suspended 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. **Who it applies to:** Companies that make explicit environmental claims to consumers. **Deadlines:** - 2023-03-22 — The Commission presents the proposal - 2025-06-20 — Announcement of intention to withdraw: negotiations suspended **What companies need to do:** - Continue to base every claim on verifiable data, as Directive 2024/825 already requires #### [Right to Repair Directive](https://www.gruppogm.eu/en/esg-regulations/right-to-repair-directive) - Legal reference: Directive (EU) 2024/1799 - Status: In force - Official text: EUR-Lex · Directive (EU) 2024/1799 — https://eur-lex.europa.eu/eli/dir/2024/1799/oj/eng 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. **Who it applies to:** Manufacturers, importers and distributors of durable consumer goods; repairers. **Deadlines:** - 2024-07-30 — Entry into force of the directive - 2026-07-31 — Application in all Member States **What companies need to do:** - Organise the repair service, spare parts and indicative prices - Prepare the European Repair Information Form #### [New Construction Products Regulation (CPR)](https://www.gruppogm.eu/en/esg-regulations/construction-products-regulation) - Legal reference: Regulation (EU) 2024/3110 - Status: Phased application - Official text: EUR-Lex · Regulation (EU) 2024/3110 — https://eur-lex.europa.eu/eli/reg/2024/3110/oj/eng 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. **Who it applies to:** Manufacturers, importers and distributors of construction products. **Deadlines:** - 2025-01-07 — Entry into force of the regulation - 2026-01-08 — General application (coexisting with the previous regulation for standards not yet updated) - 2030-01-01 (estimate) — Phased extension of mandatory environmental indicators **What companies need to do:** - Prepare for the declaration of performance with environmental indicators (EPD) - Follow the harmonised technical specifications for your product ### Climate, energy and emissions #### [CBAM — Carbon Border Adjustment Mechanism](https://www.gruppogm.eu/en/esg-regulations/cbam) - Legal reference: Regulation (EU) 2023/956 · simplification Regulation (EU) 2025/2083 - Status: Phased application - Official text: EUR-Lex · Regulation (EU) 2023/956 — https://eur-lex.europa.eu/eli/reg/2023/956/oj/eng 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. **Who it applies to:** Importers of CBAM goods above 50 t/year; indirectly, non-EU producers that supply data on embedded emissions. **Deadlines:** - 2023-10-01 — Start of the transitional phase with quarterly reports - 2026-01-01 — Definitive regime: mandatory authorisation, 50 t/year threshold - 2026-03-31 — Deadline for authorisation applications allowing imports to continue - 2027-02-01 — Sale of CBAM certificates begins - 2027-08-31 — First annual declaration (2026 emissions) and surrender of certificates - 2034-01-01 — End of free ETS allowances for CBAM sectors: full price **What companies need 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 #### [ETS2 — Emissions trading for buildings and road transport](https://www.gruppogm.eu/en/esg-regulations/ets2) - Legal reference: Directive (EU) 2023/959, amending Directive 2003/87/EC - Status: Postponed - Official text: EUR-Lex · Directive (EU) 2023/959 — https://eur-lex.europa.eu/eli/dir/2023/959/oj/eng 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. **Who it applies to:** Fuel suppliers; indirect impact on company fleets, logistics and building heating. **Deadlines:** - 2024-01-01 — Permit requirement and emissions monitoring - 2025-04-30 — First emissions reporting (year 2024) - 2028-01-01 — Launch of the market and surrender of allowances (postponed from 2027) **What companies need to do:** - Estimate the cost impact on fleets and heating - Plan electrification and efficiency measures before the launch #### [European Climate Law: −55% by 2030, −90% by 2040](https://www.gruppogm.eu/en/esg-regulations/european-climate-law) - Legal reference: Regulation (EU) 2021/1119 and amendment on the 2040 target - Status: In force - Official text: EUR-Lex · Regulation (EU) 2021/1119 — https://eur-lex.europa.eu/eli/reg/2021/1119/oj/eng 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. **Who it applies to:** Member States and EU institutions: it is the framework that guides the ETS, CBAM, energy, buildings and transport. **Deadlines:** - 2021-07-29 — Entry into force of the Climate Law - 2026-01-01 (estimate) — Adoption of the amendment with the 2040 target - 2030-12-31 — 2030 target: −55% net emissions - 2040-12-31 — 2040 target: −90% net emissions - 2050-12-31 — Climate neutrality **What companies need to do:** - Align the company's transition plan with the 2030 and 2040 pathways #### [Energy Efficiency Directive (EED)](https://www.gruppogm.eu/en/esg-regulations/energy-efficiency-directive) - Legal reference: Directive (EU) 2023/1791 - Status: Phased application - Official text: EUR-Lex · Directive (EU) 2023/1791 — https://eur-lex.europa.eu/eli/dir/2023/1791/oj/eng 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. **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. **Deadlines:** - 2023-10-10 — Entry into force of the directive - 2024-09-15 — First reporting by data centres - 2025-10-11 — General transposition deadline - 2026-10-11 — Mandatory energy audit for companies above 10 TJ/year without a management system - 2027-10-11 — Energy management system for companies above 85 TJ/year **What companies need 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 #### [Energy Performance of Buildings Directive ("green homes")](https://www.gruppogm.eu/en/esg-regulations/epbd-energy-performance-buildings) - Legal reference: Directive (EU) 2024/1275 - Status: Phased application - Official text: EUR-Lex · Directive (EU) 2024/1275 — https://eur-lex.europa.eu/eli/dir/2024/1275/oj/eng 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. **Who it applies to:** Property owners and managers, construction companies, installers, designers, public bodies. **Deadlines:** - 2024-05-28 — Entry into force of the directive - 2026-05-29 — Transposition deadline for Member States - 2026-12-31 — Solar mandatory on new public and non-residential buildings over 250 m² - 2028-01-01 — New public buildings zero-emission - 2030-01-01 — All new buildings zero-emission; 16% of the worst-performing non-residential buildings renovated - 2033-01-01 — 26% of the worst-performing non-residential buildings renovated - 2040-01-01 — Phase-out of fossil fuel boilers **What companies need to do:** - Survey the energy class of company buildings - Plan works and solar installations using available incentives and calls for funding #### [Fluorinated Greenhouse Gases Regulation (F-gas)](https://www.gruppogm.eu/en/esg-regulations/f-gas-regulation) - Legal reference: Regulation (EU) 2024/573 - Status: Phased application - Official text: EUR-Lex · Regulation (EU) 2024/573 — https://eur-lex.europa.eu/eli/reg/2024/573/oj/eng 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. **Who it applies to:** Users of refrigeration and air-conditioning systems, installers, producers and importers of equipment. **Deadlines:** - 2024-03-11 — Entry into force of the regulation - 2025-01-01 — First new bans for equipment using high-GWP gases - 2027-01-01 — Bans on self-contained heat pumps and air conditioners with a GWP of 150 or more - 2032-01-01 — Further bans for split systems **What companies need to do:** - Inventory the systems and gases used; plan their replacement - Check operator certifications and leak records ### Supply chain and due diligence #### [CSDDD — Corporate Sustainability Due Diligence Directive](https://www.gruppogm.eu/en/esg-regulations/csddd) - Legal reference: Directive (EU) 2024/1760 · Stop-the-clock Directive (EU) 2025/794 · Omnibus I - Status: Postponed - Official text: EUR-Lex · Directive (EU) 2024/1760 — https://eur-lex.europa.eu/eli/dir/2024/1760/oj/eng 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. **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. **Deadlines:** - 2024-07-25 — Entry into force of the directive - 2025-04-17 — "Stop-the-clock": one-year postponement of application - 2026-02-01 (estimate) — Omnibus I: thresholds of 5,000 employees and €1.5 billion - 2028-07-26 — Transposition deadline for Member States - 2029-07-26 — Application of the due diligence obligations **What companies need to do:** - Prepare for ESG questionnaires, audits and clauses requested by large customers - Map the social and environmental risks of your suppliers #### [EUDR — EU Deforestation Regulation](https://www.gruppogm.eu/en/esg-regulations/eudr) - Legal reference: Regulation (EU) 2023/1115 · postponements 2024/3234 and December 2025 - Status: Postponed - Official text: EUR-Lex · Regulation (EU) 2023/1115 — https://eur-lex.europa.eu/eli/reg/2023/1115/oj/eng 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. **Who it applies to:** Operators and traders of any size that place the listed commodities and products on the EU market or export them. **Deadlines:** - 2023-06-29 — Entry into force of the regulation - 2024-12-30 — Original date of application, postponed by one year - 2026-04-30 — Commission review on simplification - 2026-12-30 — Application for large and medium-sized companies - 2027-06-30 — Application for micro and small enterprises **What companies need 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 #### [Regulation prohibiting products made with forced labour](https://www.gruppogm.eu/en/esg-regulations/forced-labour-regulation) - Legal reference: Regulation (EU) 2024/3015 - Status: Forthcoming - Official text: EUR-Lex · Regulation (EU) 2024/3015 — https://eur-lex.europa.eu/eli/reg/2024/3015/oj/eng 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. **Who it applies to:** All economic operators, including e-commerce and importers. **Deadlines:** - 2024-12-13 — Entry into force of the regulation - 2026-06-14 (estimate) — Commission guidelines and risk database - 2027-12-14 — Application of the ban **What companies need to do:** - Assess supply chain risks for sensitive countries and sectors - Include clauses and checks in supply contracts ### Labour, governance and standards #### [Pay Transparency Directive](https://www.gruppogm.eu/en/esg-regulations/pay-transparency-directive) - Legal reference: Directive (EU) 2023/970 - Status: Phased application - Official text: EUR-Lex · Directive (EU) 2023/970 — https://eur-lex.europa.eu/eli/dir/2023/970/oj/eng 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%. **Who it applies to:** All employers for transparency; reporting obligation for companies with at least 100 employees. **Deadlines:** - 2023-06-06 — Entry into force of the directive - 2026-06-07 — Transposition deadline: information rights and transparency in recruitment - 2027-06-07 — First pay gap report for companies with at least 150 employees (2026 data) - 2031-06-07 — First report for companies with 100 to 149 employees **What companies need 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 #### [European Accessibility Act for products and services](https://www.gruppogm.eu/en/esg-regulations/european-accessibility-act) - Legal reference: Directive (EU) 2019/882 · Legislative Decree 82/2022 - Status: In force - Official text: EUR-Lex · Directive (EU) 2019/882 — https://eur-lex.europa.eu/eli/dir/2019/882/oj/eng - Official text: Normattiva · D.Lgs. 82/2022 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2022;82 Sets accessibility requirements for e-commerce, banking services, transport, e-books, terminals and other digital products and services. Micro-enterprises providing services are exempt. **Who it applies to:** Companies that sell online or offer digital services to consumers; device manufacturers. **Deadlines:** - 2022-07-16 — Entry into force of the Italian transposing decree - 2025-06-28 — Application of the accessibility requirements - 2030-06-28 — End of the transitional period for services based on products already in use **What companies need to do:** - Check your website and e-commerce against the requirements (standard EN 301 549) - Publish the accessibility statement for the service #### [Revision of ISO 14001 and ISO 9001 and climate change](https://www.gruppogm.eu/en/esg-regulations/iso-14001-9001-2026) - Legal reference: ISO/IAF 2024 Amendment · ISO 14001:2026 · ISO 9001:2026 - Status: Phased application 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. **Who it applies to:** Organisations that are certified or wish to become certified, particularly in order to take part in tenders. **Deadlines:** - 2024-02-23 — "Climate action" amendment to all management system standards - 2026-04-01 (estimate) — Publication of the new ISO 14001:2026 - 2026-09-01 (estimate) — Publication of the new ISO 9001:2026 (expected) - 2029-04-01 (estimate) — Indicative end of the transition for ISO 14001 **What companies need to do:** - Include climate in the analysis of context and risks - Plan the transition to the new editions with your certification body ### EU–China: trade and investment #### [FSR — Foreign Subsidies Regulation (foreign subsidies distorting the internal market)](https://www.gruppogm.eu/en/esg-regulations/fsr-foreign-subsidies-regulation) - Legal reference: Regulation (EU) 2022/2560 - Status: In force - Official text: EUR-Lex · Regulation (EU) 2022/2560 — https://eur-lex.europa.eu/eli/reg/2022/2560/oj/eng 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. **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. **Deadlines:** - 2023-01-12 — Regulation enters into force - 2023-07-12 — Application: the Commission can open ex officio investigations - 2023-10-12 — Notification obligation for concentrations and public tenders above the thresholds - 2026-07-12 — Commission report on the functioning of the Regulation **What companies need 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 #### [IPI — International Procurement Instrument](https://www.gruppogm.eu/en/esg-regulations/ipi-international-procurement-instrument) - Legal reference: Regulation (EU) 2022/1031 - Status: In force - Official text: EUR-Lex · Regulation (EU) 2022/1031 — https://eur-lex.europa.eu/eli/reg/2022/1031/oj/eng 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. **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. **Deadlines:** - 2022-08-29 — Regulation enters into force - 2025-06-01 (estimate) — First measure: medical devices of Chinese origin excluded from tenders above €5 million **What companies need 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 #### [China: sustainability reporting by listed companies and national standards](https://www.gruppogm.eu/en/esg-regulations/china-sustainability-disclosure) - Legal reference: Shanghai, Shenzhen and Beijing Stock Exchanges Guidelines for Sustainability Reporting (April 2024) · Ministry of Finance Basic Standard for Corporate Sustainability Disclosure (December 2024) - Status: Phased application 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. **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. **Deadlines:** - 2024-04-12 — The Shanghai, Shenzhen and Beijing stock exchanges publish the guidelines - 2024-05-01 — Guidelines enter into force - 2024-12-01 (estimate) — The Ministry of Finance publishes the Basic Standard for Corporate Sustainability Disclosure - 2026-04-30 — Deadline for the first mandatory reports (financial year 2025) - 2030-01-01 (estimate) — Target: unified national system of disclosure standards **What companies need to do:** - Prepare for ESG data requests from listed Chinese customers - Align data already collected for the CSRD and VSME with Chinese requirements #### [China's national emissions trading market and "dual carbon" goals](https://www.gruppogm.eu/en/esg-regulations/china-national-carbon-market-ets) - Legal reference: State Council Interim Regulations on the Administration of Carbon Emissions Trading (2024) - Status: Phased application 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. **Who it applies to:** Large Chinese installations in the covered sectors; indirectly, European importers and companies with production in China. **Deadlines:** - 2021-07-16 — National market launched with the power sector - 2024-05-01 — State Council Interim Regulations enter into force - 2025-03-01 (estimate) — Extension to steel, cement and aluminium - 2030-12-31 (estimate) — Target: CO₂ emissions peak before 2030 - 2060-12-31 (estimate) — Target: carbon neutrality before 2060 **What companies need to do:** - Monitor installation emissions using methods compatible with CBAM - Document the carbon price paid in China for discussions with EU importers ### EU–Japan: trade and sustainability #### [EU–Japan Economic Partnership Agreement](https://www.gruppogm.eu/en/esg-regulations/eu-japan-economic-partnership-agreement) - Legal reference: Council Decision (EU) 2018/1907 · Protocol on cross-border data flows - Status: In force - Official text: EUR-Lex · Decision (EU) 2018/1907 — https://eur-lex.europa.eu/eli/dec/2018/1907/oj/eng 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. **Who it applies to:** Italian exporters to Japan (agri-food, wine, fashion, machinery, chemicals) and Japanese companies selling in Europe. **Deadlines:** - 2019-02-01 — Entry into force of the agreement - 2024-07-01 (estimate) — Entry into force of the protocol on cross-border data flows **What companies need 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 #### [Japan: SSBJ sustainability standards for listed companies](https://www.gruppogm.eu/en/esg-regulations/japan-ssbj-sustainability-standards) - Legal reference: Standards of the Sustainability Standards Board of Japan (March 2025), aligned with ISSB IFRS S1 and S2 - Status: Forthcoming 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. **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. **Deadlines:** - 2025-03-05 — Publication of the SSBJ standards - 2027-03-31 (estimate) — Expected obligation for Prime companies with a market capitalisation of at least ¥3 trillion (financial years ending March 2027) - 2028-03-31 (estimate) — Expected extension to companies with a market capitalisation of at least ¥1 trillion - 2029-03-31 (estimate) — Expected extension to companies with a market capitalisation of at least ¥500 billion **What companies need to do:** - Prepare for emissions data requests from Japanese customers - Reuse data collected for CSRD and VSME in an ISSB-compatible format #### [Japan: GX-ETS and “Green Transformation” carbon pricing](https://www.gruppogm.eu/en/esg-regulations/japan-gx-ets-carbon-pricing) - Legal reference: GX Promotion Act (2023) and subsequent amendments - Status: Phased application 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. **Who it applies to:** Large Japanese emitters (over 100,000 tonnes of CO₂ a year), fossil fuel importers, power generators; indirectly, their European partners. **Deadlines:** - 2023-04-01 (estimate) — Launch of the voluntary phase with the GX League - 2023-05-01 (estimate) — Adoption of the GX Promotion Act - 2026-04-01 (estimate) — Mandatory participation in the GX-ETS for large emitters - 2028-04-01 (estimate) — Expected launch of the fossil fuel levy - 2033-04-01 (estimate) — Expected launch of allowance auctions for the power sector **What companies need 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 #### [Japan: Plastic Resource Circulation Act](https://www.gruppogm.eu/en/esg-regulations/japan-plastic-resource-circulation-act) - Legal reference: Plastic Resource Circulation Act (in force since 1 April 2022) - Status: In force 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. **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. **Deadlines:** - 2022-04-01 — Entry into force of the Act **What companies need 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 ### Italy: national requirements #### [RENTRI — National electronic waste traceability register](https://www.gruppogm.eu/en/esg-regulations/rentri) - Legal reference: Ministerial Decree no. 59 of 4 April 2023 · Legislative Decree 152/2006, Art. 188-bis - Status: Phased application - Official text: Normattiva · D.Lgs. 152/2006 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2006;152 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. **Who it applies to:** Producers of hazardous special waste and of certain non-hazardous waste, carriers, facilities, brokers. **Deadlines:** - 2024-12-15 — Registration opens - 2025-02-13 — Registration for producers with more than 50 employees and for waste management operators - 2025-08-14 — Registration for producers with more than 10 employees - 2026-02-13 — Registration for all other obligated parties; digital FIR for everyone **What companies need to do:** - Check your phase and confirm that registration has been completed - Switch to the digital register and form, using interoperable software #### [CAM (Minimum Environmental Criteria) in public procurement](https://www.gruppogm.eu/en/esg-regulations/cam-green-public-procurement-italy) - Legal reference: Legislative Decree 36/2023, Art. 57 · corrective Legislative Decree 209/2024 · sector-specific CAM decrees - Status: In force - Official text: Normattiva · D.Lgs. 36/2023 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2023;36 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. **Who it applies to:** All companies that take part in public tenders. **Deadlines:** - 2023-07-01 — The new Public Contracts Code takes effect - 2024-12-31 — The corrective decree to the Code enters into force - 2025-01-01 (estimate) — Ongoing updates to sector-specific CAM decrees **What companies need to do:** - Know the CAM in force in your sector and the evidence required - Highlight certifications, LCAs and EPDs in the technical bid #### [Environmental labelling of packaging (Italy)](https://www.gruppogm.eu/en/esg-regulations/packaging-environmental-labelling-italy) - Legal reference: Legislative Decree 152/2006, Art. 219(5) (introduced by Legislative Decree 116/2020) - Status: In force - Official text: Normattiva · D.Lgs. 116/2020 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2020;116 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. **Who it applies to:** Producers and users of packaging sold in Italy. **Deadlines:** - 2023-01-01 — The obligation enters into force - 2028-08-12 — Replacement by the harmonised PPWR label **What companies need to do:** - Check codes and collection information on all packaging - Plan the switch to the future EU label #### [Plastic tax and sugar tax](https://www.gruppogm.eu/en/esg-regulations/italy-plastic-tax-sugar-tax) - Legal reference: Law 160/2019, Art. 1(634–658) and (661–676) · 2026 Budget Law - Status: Postponed - Official text: Normattiva · L. 160/2019 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2019;160 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. **Who it applies to:** Manufacturers, importers and purchasers of MACSI from other EU countries; producers and importers of sweetened beverages. **Deadlines:** - 2020-01-01 — Introduced by the 2020 Budget Law - 2027-01-01 — Currently scheduled start date **What companies need 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 #### [Mandatory insurance against natural catastrophes](https://www.gruppogm.eu/en/esg-regulations/italy-mandatory-catastrophe-insurance) - Legal reference: Law 213/2023, Art. 1(101–111) · Decree-Law 39/2025 - Status: In force - Official text: Normattiva · L. 213/2023 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2023;213 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. **Who it applies to:** All companies entered in the Companies Register, with different deadlines by size (agricultural businesses excluded). **Deadlines:** - 2025-03-31 — Obligation for large companies - 2025-10-01 — Obligation for medium-sized companies - 2025-12-31 — Obligation for small and micro enterprises **What companies need to do:** - Check cover on capital goods - Keep the policy: it is a condition for accessing calls for funding and incentives #### [Gender equality certification UNI/PdR 125:2022](https://www.gruppogm.eu/en/esg-regulations/gender-equality-certification-uni-pdr-125) - Legal reference: Law 162/2021 · UNI/PdR 125:2022 · Legislative Decree 36/2023 - Status: In force - Official text: Normattiva · L. 162/2021 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2021;162 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. **Who it applies to:** Companies of all sizes, especially those taking part in tenders or calls for funding. **Deadlines:** - 2022-03-16 — Publication of the UNI/PdR 125 reference practice - 2023-07-01 — Award points in the new Public Contracts Code **What companies need 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 #### [Whistleblowing: internal reporting channels](https://www.gruppogm.eu/en/esg-regulations/italy-whistleblowing-decree-24-2023) - Legal reference: Legislative Decree 24/2023 (Directive (EU) 2019/1937) - Status: In force - Official text: Normattiva · D.Lgs. 24/2023 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2023;24 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). **Who it applies to:** Private companies with at least 50 employees and those with a Model 231, regardless of headcount. **Deadlines:** - 2023-07-15 — Obligation for companies with at least 250 employees - 2023-12-17 — Obligation for companies with 50 to 249 employees **What companies need to do:** - Set up a confidential channel, which may be digital, and a written procedure - Train the person managing the reports #### [Transizione 5.0 Plan](https://www.gruppogm.eu/en/esg-regulations/transizione-5-0-tax-credit) - Legal reference: Decree-Law 19/2024, Art. 38 · implementing Ministerial Decree of 22 July 2024 - Status: In force - Official text: Normattiva · D.L. 19/2024 — https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legge:2024;19 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. **Who it applies to:** Companies resident in Italy that invested in 2024–2025. **Deadlines:** - 2024-03-02 — Establishment of the plan - 2024-08-07 — GSE booking platform opens - 2025-12-31 — Deadline for completing eligible investments **What companies need to do:** - Keep ex post certifications and documentation for inspections - Assess the new measures for investments from 2026