Written by Marc Lütz
Dear reader,
After a baking summer, Brussels is back at its desks, back in committee rooms and wasting little time in picking up where it left off.
This edition looks at an autumn agenda in which implementation is firmly taking centre stage. From the PPWR’s general application and further EUDR clarifications to new Right to Repair rules, the End-of-Life Vehicles Regulation and the rollout of Digital Product Passports, businesses are increasingly having to turn EU sustainability ambitions into practice. Meanwhile, a summer of record heat has sharpened the case for climate resilience, even as delivery continues to lag, and the Circular Economy Act appears set to keep Brussels waiting a little longer.
In the meantime, a little birdie told us that blog posts prepared by our sustainability team are also finding their way into Brussels WhatsApp group chats, where they are being used to check the latest policy developments. We will take that as a reassuring sign that our analysis is proving useful.
The spotlight
Climate resilience: as risks rise, so do costs, yet delivery lags
Researchers have estimated that this summer’s extreme weather could cost EU economies €180 billion, or approximately 1% of the bloc’s GDP. In France alone, insurers report costs of nearly €500 million. These costs are estimated to grow as temperatures continue to rise: this August was the hottest in recorded history, with ocean temperatures breaking heat records over 100 consecutive days. Increased exposure to climate hazards such as wildfires, floods, and droughts is adding pressure to the EU’s climate adaptation and resilience agenda.
It is against this backdrop that the European Commission will present its Climate Resilience Framework on 28 October. The framework is expected to move the EU from reactive crisis response to a more anticipatory, risk-based approach – one that integrates climate adaptation and disaster risk reduction into investment decisions, infrastructure planning, and supply-chain management. The case for such a shift was laid out in January 2026, when a study commissioned by DG CLIMA concluded that the EU should invest around €70 billion annually in climate adaptation measures, with €30 billion for infrastructure, €21 billion for ecosystems, and €12 billion for food security. Given the urgency and scale of the challenges, the researchers deemed the current financing insufficient.
Meanwhile the implementation of the EU’s Nature Restoration Regulation is struggling to keep pace with these increasing challenges. On 1 September, the European Parliament’s Environment (ENVI) Committee held an exchange of views with the Commission on the implementation of the Regulation, focused on the national restoration plans due that day. MEPs criticised the short deadlines in the process, arguing they prevented proper stakeholder involvement. Several MEPs also raised the lack of clarity on financing needs. The Commission indicated that the national plans will feed into programming for the next Multiannual Financial Framework (MFF). Yet MFF negotiations are likely to precede the approval of national restoration plans, reducing member states’ prospects of securing MFF funding for them. That concern looks harder to dismiss given that, despite a 1 September deadline, only eight member states have submitted their plans as of 10 September.
Impact analysis for your business
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Policy updates
The Packaging and Packaging Waste Regulation enters into force
Since 12 August, the Packaging and Packaging Waste Regulation (PPWR) generally applies across the EU. While requirements on documentation, traceability, conformity assessment, substances of concern and EPR now apply, major obligations on recyclability, recycled content, minimisation and reuse will largely follow from 2030 onwards.
Ahead of this date, the Commission published updated FAQs on 3 August. These clarify manufacturer and producer responsibilities, including for transport packaging and stretch wrap, and provide further guidance on conformity assessments and demonstrating compliance with substances-of-concern requirements. Packaging produced before 12 August does not need to be remanufactured or relabelled and may use accompanying documentation for certain identification requirements. The first harmonised PPWR EPR reporting deadline will be 1 June 2030.
For more information about the PPWR, please read our blog post dedicated to the subject.
EU Commission further clarifies EUDR scope and guidelines over the summer
The European Commission continues to refine its implementation guidelines for the European Union Deforestation Regulation (EUDR) ahead of its general application date. Recent clarifications aim to ease compliance burdens while maintaining strict environmental oversight.
To simplify compliance for smaller producers, the updated FAQs establish a streamlined regime for Micro and Small Primary Operators (MSPOs) in low-risk countries, requiring only a one-time geolocation entry. Primary due diligence obligations fall on the initial party placing goods on the EU market, while transport packaging used solely for transport purposes remains exempt.
Following stakeholder consultation, a delegated acted adopted on 13 July 2026 formally refined the covered product categories, retaining items such as sawmill wood residues while adjusting low-impact entries. In a written answer from 25 August 2026, Environmental Commissioner Jessika Roswall clarified that EUDR product coverage is defined specifically by the degree to which EU market demand of such product drives deforestation, rather than a raw material’s total global environmental impact alone.
The general application deadline remains 30 December 2026 for large and medium-sized enterprises, and 30 June 2027 for MSPOs. A comprehensive evaluation of the regulation’s effectiveness is slated for completion by 30 June 2030.
Right to Repair rules take effect across the EU
On 31 July, the EU’s Right to Repair Directive became applicable, following a two-year period for Member States to transpose the rules into national law. Adopted in 2024, the Directive aims to make repairing products easier and more attractive than replacing them. Among other measures, consumers who choose repair over replacement during the legal guarantee period will benefit from an extension of the guarantee by at least 12 months. For certain products covered by EU repairability requirements, manufacturers must also offer repairs beyond the legal guarantee period at a reasonable price.
Looking ahead, the Commission is developing a European online platform for repair, which will help consumers find repairers and sellers of refurbished goods across the EU and is expected to become operational in January 2028. A report published by Right to Repair Europe on 7 September raises concerns about compliance with existing EU repairability requirements for smartphones, finding that only 18% of smartphones placed on the market in 2025 provided the required information on spare parts and repairs. Looking ahead, the EU repair framework will continue to develop as repairability requirements are expected to be extended to additional product groups.
End-of-Life Vehicles Regulation adopted and Ecodesign enters implementation phase
On 8 July, the EU adopted the End-of-Life-Vehicles Regulation (ELVR), replacing the End-of-Life-Vehicles Directive and the 3R Type-Approval Directive . The new Regulation is designed to enhance circularity in the automotive sector by reducing waste, increasing the recovery of valuable and critical raw materials, and supporting the EU’s broader sustainable competitiveness agenda. Although most obligations are deferred, key changes include new circular design requirements (including recycled content requirements), an extension of the scope to additional vehicle categories, restrictions on the export of end-of-life vehicles and the introduction of an EPR scheme.
In parallel to the ELVR, the implementation of the Ecodesign for Sustainable Products Regulation (ESPR) has accelerated significantly. The Commission’s Digital Product Passport (DPP) Registry became operational on 20 July, marking the main shift from framework development to implementation phase. Alongside this, the Commission established the DPP Registry framework, adopting six out of the eight harmonised standards required to support it. The remaining two are set to be adopted during the month of September 2026.
Looking ahead, the Commission is expected to develop a harmonised definition of “low-carbon steel” through the ESPR iron and steel products delegated act currently planned for Q2 2027 to ensure alignment with the Industrial Accelerator Act.
Circular Economy Act remains delayed towards the end of the year
The European Commission’s proposal for the Circular Economy Act (CEA), previously expected in September, has been delayed after its impact assessment reportedly did not receive the necessary green light from the Commission’s Regulatory Scrutiny Board. A negative opinion requires the assessment to be revised and resubmitted before the proposal can normally proceed. The Commission now states that the CEA is due before the end of 2026, with rumors suggesting publication toward the latter half of November and December pending a new review by the RSB expected in mid-October.
In addition to the delay in the publication of the CEA, there have been some changes in the Commissions taskforce for the CEA. The Commission official who served as Taskforce Leader for the Circular Economy Act in DG Environment has moved to the Cabinet of Commissioner for Sustainable Transport and Tourism Apostolos Tzitzikostas. It has not yet been publicly confirmed who will take over the role. Meanwhile, work on the proposal continues, with the Commission’s recent Youth Check feeding into the ongoing impact assessment ahead of the proposal’s expected publication later this year.
For more background on the CEA and its development, read our Publyon deep dive on the Circular Economy Act.
Blog
Packaging and Packaging Waste Regulation: is your business ready for new packaging requirements?
The Packaging and Packaging Waste Regulation is the EU’s new directly applicable framework for packaging and packaging waste. Since 12 August 2026, it generally applies across the European Union.
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