Key Sustainability Regulations to Watch 2025 Outlook

Sustainable Claims and Marketing

EU Green Claims Directive

2024 Development: The European Council adopted it in June 2024 which marked a key step in legislation process. The directive aims to standardize how companies substantiate environmental claims, requiring independent verification and prohibiting generic claims like "eco-friendly" without specific and scientific proof.

2025 Outlook: Trilogue negotiation between Parliament and Council to continue through 2025. Formal adoption and publication of the Directive are expected. After that, Member States will have time to transpose it into national law.

The first trilogue on Green Claims took place on 28 January 2025, during which the Parliament and the Council presented their mandates and priorities. This proposed Directive is about substantiation and communication of explicit environmental claims. In a nutshell, Parliament's position provides for:

Environmental marketing claims like "biodegradable" or "less polluting" to be submitted for verification before companies may use them
Simpler and common types of claims to benefit from easier or faster verification
Penalties including exclusion from procurement processes, confiscation of revenues, and a fine of at least 4% of annual turnover.

Businesses should prepare for stricter requirements on substantiating environmental claims, potentially including:

Verify environmental claims before making them
Substantiate environmental claims with scientific evidence
Obtain third-party verification for claims before being published
Life-cycle perspective assessment is required for environmental claims

LEARN MORE
Stopping greenwashing: how the EU regulates green claims
BV Sustainable claim solutions

UK CMA Green Codes

2024 Development: The CMA published new practical guidance specific for the fashion sector on environmental claims. emphasizing transparency and adherence to the Green Claims Code.

2025 Outlook:

The Digital Markets, Competition and Consumers Act (DMCC) is expected to come into effect in April 2025. CMA will gain direct enforcement powers to impose fines of up to 10% of global turnover for breaches of consumer law.
Businesses selling in the UK must ensure their environmental claims comply with the CMA Code's principles. The six key principles require that claims must:
- Be truthful and accurate
- Be clear and unambiguous
- Not omit or hide important information
- Compare fairly and meaningfully.
- Consider the full life cycle of the product/service
- Be substantiated with evidence.

LEARN MORE
About Green Claims
BV Sustainable claim solutions
CMA’s New Green Claim Guidance for Fashion Brands: What Businesses Need to Know?

FTC Green Guides

2024 Status: The FTC is currently undergoing a review process of the Green Guides.

2025 Outlook:

Publication of revised Green Guides are now anticipated in early-to-mid 2025. The revised Green Guides will likely address emerging issues like carbon offsets and recycled content by providing new standards for claims.
Companies selling in the US must stay informed about the updated Green Guides and ensure their environmental claims comply with the new guidance to avoid potential enforcement actions.
The impact of the Trump administration on US sustainability is still unfolding and require close monitoring and analysis over time.

LEARN MORE
Environmentally Friendly Products: FTC’s Green Guides
BV Sustainable claim solutions

Supply Chain Due Diligence

Corporate Sustainability Due Diligence Directive (CSDDD)

2024 Development: The Corporate Sustainability Due Diligence Directive (CSDDD) was adopted, published and entered in force in July 2024, introducing mandatory human rights and environmental due diligence obligations for companies operating in the EU.

2025 Outlook: Expected to be finalized and will require companies to align their operations with its due diligence obligations for its phased implementation starting in 2027. It imposes mandatory due diligence obligations on companies to address human rights and environmental risks across their value chains. The phased implementation schedule is as follows:

Member States must transpose the directive into national law by July 26, 2026
Companies will need to comply in three phases starting from 2027:
- 2027: EU companies with >5,000 employees and €1 500 million global turnover, as well as non-EU companies with more than €1 500 million turnover generated in the EU
- 2028: EU companies with >3,000 employees and €900 million global turnover, as well as non-EU companies with more than €900 million turnover generated in the EU
- 2029: EU companies with >1,000 employees and €450 million global turnover, as well as non-EU companies that meet certain criteria

Companies will need to establish due diligence processes to identify, prevent, mitigate, and account for potential and actual adverse human rights and environmental impacts in their supply chains.

LEARN MORE
About Corporate Sustainability Due Diligence Directive
CSDDD FAQ

EU Deforestation Regulation (EUDR)

2024 Development: The European Parliament approved a one-year postponement of the EUDR's application date. The new compliance deadlines are set for December 30, 2025, for large companies, and June 30, 2026, for micro and small enterprises.

2025 Outlook:

The EU will also finalize the classification of countries into low, standard, or high deforestation risk categories, which will influence the level of due diligence required.
Companies are required to map their supply chains, collect geolocation data, and conduct risk assessments to ensure compliance.

LEARN MORE
About Regulation on Deforestation-free Products

Corporate Reporting and Disclosure

Corporate Sustainability Reporting Directive (CSRD)

2024 Status: In 2024, the CSRD began its phased implementation. The first companies will have to apply the new rules for the first time in the 2024 financial year, for reports published in 2025.

2025 Outlook:

The first CSRD reports will be published in 2025, covering the 2024 financial year data from companies previously subject to Non-Financial Reporting Directive (NFRD).
The CSRD will expand its scope to include large companies not previously covered under the NFRD. These companies will need to comply with the directive for financial years starting on or after January 1, 2025, with reports due in 2026.These companies must comply if they meet two of three criteria: annual net turnover exceeding €50 million, balance sheet exceeding €25 million, or at least 250 employees.
The European Union is preparing to introduce an “Omnibus Simplification Package” that will consolidate three major sustainability regulations: CSRD, CSDDD, and the EU Taxonomy Regulation. This initiative, first announced by EU Commission President in November 2024, aims to reduce reporting requirements while maintaining the core standards of sustainability reporting. The Omnibus regulation is expected to be published in February 2025.

LEARN MORE
About Corporate sustainability reporting

Product Sustainability & Environmental Performance

Ecodesign for Sustainable Products Regulation (ESPR) n° 2024/1781

2024 Development: The ESPR was published in June 2024 and entered into force in July 2024, replacing Ecodesign Directive 2009/125/EC for Energy-related Products and introduces three main changes: rules on Digital Product Passports (DPPs), green public procurement, and restrictions on the destruction of unsold products.

Both Energy-Related Products Directive (ErP) and ESPR Regulation are framework regulations. They are implemented through their implementation regulations, published mostly per product groups.

Today, there are already around 30 regulations implementing ErP Directive. They will be progressively repealed and revised in order to add new circular economy and sustainability aspects such as durability, repairability, reusability, recyclability.

As for the transitional period (from ErP to ESPR), implementing regulations related to the 19 products (ErP) on the left of the EU Commission presentation below should be revised or published by the end of 2026 under the ongoing working plan. The products on the right will be covered by implementing regulations under the first ESPR WP. However, work on these latter products has not progressed.

2025 Outlook: The first ESPR Working Plan is expected to be adopted and published in the first half of 2025. Priority products for the first working plan include Iron & steel, aluminium, textiles (garments and footwear), furniture (including mattresses), tyres, detergents, paints, lubricants, chemicals, energy-related products and ICT products.
Companies need to prepare and consider the environmental impact of their products throughout their lifecycle.

LEARN MORE
Ecodesign for Sustainable Products Regulation Implementing the Ecodesign for Sustainable Products Regulation EU Framework Regulation for Setting ESPR
List of energy efficient products regulations: by product group
EU Eco-design Regulations 2024/1781

Content is intended to provide general information only and does not constitute legal advice. Information in this article is accurate as of Jan 2025.

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