ESG & legislation

Moore ESG and legislation

This ESG legislation page is compiled with great care and updated regularly. Moore aims to reflect the most current state of affairs, but cannot guarantee that the information will be complete or error-free at all times. Therefore, please use this content as a general guide and consult our experts and advisers for the latest insights and updates.

Omnibus package 

This collection guideline gives companies extra breathing space by temporarily deferring  and simplifying some of the existing reporting and due-diligence requirements.

Stop-the-Clock

Timeline: 

• 14 April 2025 adopted, member states transpose rules by 31 December 2025. 
• CSRD reporting for large companies shifts to financial year 2027 (publication 2028) and for listed SMEs to financial year 2028 (publication 2029).

CSRD & VSME standard

The Corporate Sustainability Reporting Directive adds a full-fledged sustainability chapter (ESRS) to the annual report. A simplified VSME standard is available for small unlisted SMEs.

Timeline:

• CSRD: 
  • EFRAG is working on an exposure draft of the simplified ESRS standards, scheduled for publication at the end of July 2025. The public (stakeholder) consultation will run until the end of September, after which the final advice will be delivered to the European Commission by 30 November 2025. This should result in a simplification of sustainability reporting under CSRD. 
• VSME:
• By 30 July 2025, the European Commission has included an official recommendation of the VSME standard as a voluntary reporting standard for SMEs. 

ESPR & Digital Product Passport

The Ecodesign for Sustainable Products Regulation imposes ecodesign requirements and links each product to a digital passport with environmental and origin data.

Product scope (first priority wave): iron & steel, aluminium, textiles, furniture, tyres, detergents, paints, lubricants, basic chemicals, energy-related products and ICT/electronics. 

When does a company fall under ESPR?

• You produce, import or distribute physical goods placed on the EU market (almost all products except food, pharmaceuticals and vehicles, among others).
• There is no threshold for turnover or staff size; SME importers must also comply. 

Timeline:

• 13 June 2024: Final adoption ESPR the Ecodesign for Sustainable Products Regulation; regulation published as Regulation (EU) 2024/17811.
• 18 July 2024: ESPR enters into force; starting point for secondary legislation (delegated acts).
• 2025-2026: Development of delegated acts for product groups and technical standards for DPP Digital Product Passport (incl. interoperability, APIs, data models)
• No later than 19 July 2026: EU-wide DPP registry operational (central database for all product passports)
• Q1-Q2 2026: Delegated act for DPP service providers (requirements for hosting, data integrity, certification)
• 18 February 2027: DPP mandatory for batteries (industrial and EV batteries >2 kWh) under EU Battery Regulation (EU 2023/1542)
• 2027: Start obligation for textiles and furniture (expected via delegated acts)
• 2028: Electronics & ICT (consumer electronics, household appliances)
• 2030: Building materials and other categories (full market coverage)
• 2030: DPP mandatory for all priority product groups; full integration into circular economy policies

EUDR - EU Deforestation Regulation

This regulation prohibits importation or sale of raw materials as well as derived products linked to deforestation after 31-12-2020.
 

Commodities: wood, cocoa, coffee, soy, rubber, beef (including leather) and palm oil; plus products such as chocolate, furniture and tyres.

Application criteria:

• You are operator (producer/importer) or trader and bring the above goods into or export them from the EU market.
• Each lot must be traceable to the plot (geographical coordinates) and accompanied by a due-diligence statement.
• Micro and small enterprises will have slightly lighter obligations, but no exemption.

Timeline: 

• 30 June 2025: High-risk countries are classified.
• 30 December 2025: Large and medium-sized enterprises must be fully compliant.
• 30 June 2026: Deadline for micro and small enterprises.

CBAM linked to EU ETS

The Carbon Border Adjustment Mechanism levies a carbon price on imported emissions-intensive goods from 2026.

Sectors/products: iron & steel (raw materials and some semi-finished products), cement and clinker, aluminium, fertilisers (basic chemicals), electricity and hydrogen.

 
Application criteria:

• You import these goods into the EU and must register as a CBAM declarant.
• For each shipment, you report the process emissions of the non-EU producer; from 2026, you purchase CBAM certificates worth those emissions.
• No turnover or personnel thresholds: the obligation follows from the Commodity Code Number (CN code) at import.

Timeline (depending on Omnibus):

• Transition phase (2023-2025)
• Quarterly reporting via CBAM portal.
• Till June 2024 default values may be used, from July 2024 real emissions must be reported.
• No certificates required.
• Preparation (2025)
  • Applicate authorisation as a CBAM declarant (deadline Q3 2025).
  • New threshold: 50 tonnes per commodity category.
  • Definitive phase (from 2026)
    • Only authorised declarants may import.
    • Annual declaration by 31 August.
    • Certificates required to be bought and handed in.
    • External verification required.
  • Extension from 2027
  • Per quarterly at least 50% certificates handed in.
  • Possible expansion of product scope and start of certificate sales.
  • ETS will be systematically phased out until 2034.

Greenwashing Package (Empowering Consumers & Green Claims)

New rules against misleading environmental claims in marketing.

Main obligations:

• Every explicit or implicit environmental claim must be substantiated by a life cycle analysis or equivalent evidence.
• Vague terms such as "eco", "CO₂-neutral" or proprietary labels without verification are prohibited.

Application criteria:

• Acts to all companies promoting products or services to EU consumers.
• Micro-companies (<10 employees ánd <€2m turnover) are largely exempt, but remain liable for blatant deception. 

Timeline:

• Empowering Consumers for the Green Transition Directive:Adopted in February 2024, applicable from 27 September 2026
• Green Claims Directive: Temporarily repealed in June 2025

CSDDD - Corporate Sustainability Due Diligence Directive

This directive requires companies to identify, prevent and address environmental and human rights risks across their entire value chain - and hold the boardroom accountable for it.

Application criteria (EU companies):

• ≥ 5 000 fte & ≥ €1.5 bln turnover (from 2028)
• ≥ 3 000 fte & ≥ €900 m turnover (from 2029)
• ≥ 1 000 fte & ≥ €450 m turnover (from 2030)
  The same level of turnover applies to non-EU companies, but only on their EU turnover.  

Timeline (depending on Omnibus):

• 2024
  • 5 July: Publication of CSDD (Directive (EU) 2024/1760) in Official Journal.
  • 25 July: Directive enters into force.
  • Start national preparations.
• 2025
  • 16 April: Omnibus I ("Stop-the-clock") published → transposition + application delayed by 1 year.
  • 17 April: Omnibus I in force.
  • Omnibus II (proposal): simplifications (limit scope to Tier-1, less frequent monitoring) → still under negotiation.
• 2026
  • Member States are working on transposition → transposition deadline now 26 July 2027.
• 2027
  • 26 July: New transposition deadline (was 2026).
  • Companies start implementation projects (due diligence processes, contract clauses, governance).
• 2028
  • 26 July: First application → large enterprises (>5.000 employees / €1.5 bln) as well as medium-sized category (>3,000 / €900 mln) fall together in this wave.
• 2029
• 26 July: Second/end wave → all other in-scope companies (>1.000 / €450m + franchise/licence).

PPWR - Packaging and Packaging Waste Regulation

A new European regulation regulating packaging and packaging waste with the aim of promoting sustainability and circularity.

Objectives of the PPWR

The PPWR is part of the European Green Deal and the Circular Economy Action Plan. Its main targets are:

• Waste Prevention: Reduce empty space and unnecessary packaging.
• Recyclability: By 2030, all packaging must be fully recyclable.
• Recycled material: Mandatory percentages of recycled plastic in new packaging.
• Reusability: Packaging must be designed for multiple use.
• Labelling: Uniform pictograms and sorting labels for all of Europe.
• Restriction of hazardous substances: Such as PFAS and heavy metals in packaging materials.
• Compostability: Clear rules for compostable packaging

Impact on businesses

The PPWR applies to manufacturers, importers, distributors, packaging suppliers, e-commerce, retail and food sectors. Companies must demonstrate that their packaging complies with design, material and reporting requirements. Early compliance offers benefits such as:

• Faster access to EU markets
• Reduced risk of fines
• Strengthened reputation and customer confidence

Timeline:

• This law replaces the old directive 94/62/EC and comes into force on 12 August 2026, with phased obligations until 2040 
• From 2027: Customers will be allowed to bring their own packaging for takeaway meals at no extra cost.
• From 2029: Mandatory deposit systems for plastic and metal beverage containers in all EU countries.
• From 2030:
  • Packs must be at least 70% recyclable (class C); below that must not be allowed on the market.
  • Plastic packaging for fresh fruit and vegetables <1.5 kg will be banned.
  • Horeca must offer at least 10% of products in reusable packaging.
  • Recycled content mandatory: e.g. 30% for PET packaging
• By 2040:Waste reduction targets: 5% less packaging waste per inhabitant by 2030, rising to 15% by 2040 

With this overview, you can see at a glance what rules apply to your organisation and what to anticipate. Moore ESG will be happy to guide you through every step: from risk assessment to full implementation.