Sustainability legislation update

Summarising key changes to sustainability legislation.

Image © iStock.com/triocean

The legislative landscape for sustainability has been ever-changing in the last few years, and that has continued to be the case throughout 2025. This year has seen some key pieces of legislation being delayed or watered down, while there has been considerable progress in the development of other regulations.

The first big announcement of 2025 came from the European Commission on 26th February, with a so-called ‘Omnibus Simplification Package’. This made amendments to both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). These changes are summarised in the table in this article.

Changes within the ‘Omnibus Simplification Package’
	Before Omnibus Package	After Omnibus Package
CSRD	Obligation to report starting in 2025	Obligation to report delayed to 2028
CSRD	Thresholds for compliance: More than 250 employees More than EUR 40 million turnover and/or balance sheet of more than EUR 20 million	Thresholds for compliance: More than 1,000 employees More than EUR 50 million turnover and/or balance sheet of more than EUR 25 million
CSDDD	Phased in from 2027	Phased in from 2028

The European Union Deforestation Regulation (EUDR) was originally due to be enforced from 30th December 2024 for large companies. However, at the end of 2024 it was delayed until 30th December 2025 to allow organisations more time to prepare.

In April 2025, the European Commission published simplifications to EUDR, including the following:

The option to re-use due diligence statements (for example, if an affected item is re-imported into the EU).
Further clarification on the role of authorised representatives.
An annual submission of due diligence statements is now permitted (rather than per batch or per shipment).
Simplified obligations.

At the time of writing, the implementation of EUDR for SMEs will be delayed by six months until December 2026. While large organisations will still have to comply from 30th December 2025, enforcement activities will not start until June 2026.

Under the European Union’s Ecodesign for Sustainable Products Regulation, a working group has been formed specifically for footwear. This is due to conclude by the end of 2027. The findings of this group will likely inform the data requirements and start date for digital product passports for footwear (DPPs).

Preparing for DPPs

DPPs remain a hot topic. One of the main challenges for organisations which are likely to be affected has been the lack of clarity on when DPPs will be required and what data they will need to hold. For textiles, it now seems clear that ‘minimal’ DPPs will be required in 2027, with more detailed DPPs from 2030 and fully circular DPPs from 2033. The data requirements for a minimal DPP are:

product composition – inclusion of recycled content, the presence of dangerous substances and the presence of plastic microfibres
information about the recyclability of the product
supply chain traceability – location of main processes, including preparation, weaving, knitting and dyeing that have a significant environmental impact
information about the product’s packaging – recycled content, recyclability and possibility of re-use
information on the environmental impact and the innocuousness of the product.

As indicated above, a date has not yet been set for when footwear DPPs will be required. However, it is possible to derive from the textile requirements the type of data that is likely to be needed, which should allow organisations to start some preparatory work.

Taking responsibility

Extended Producer Responsibility (EPR) Schemes for textiles are already operational in some European countries. For instance, France has a scheme for clothing, household textiles and footwear and the Netherlands introduced a scheme for textiles (not including footwear) in 2023.

As part of the European Union’s Waste Framework Directive, all EU member states must have EPR schemes for textiles by the summer of 2028 including for clothing, accessories, footwear, and household textiles. Each member state will determine the details of its own scheme, although it is likely that discounted fees or bonuses will be made available for products which meet certain sustainability criteria.

What about packaging?

The application of the European Union’s Packaging and Packaging Waste Regulation (PPWR) will start on 12th August 2026. PPWR sets various targets relating to the sustainability of packaging including increased recycled content, increased recyclability, a reduction in packaging, safer packaging and clear labelling.

One benefit for footwear companies will hopefully be greater harmonisation of the markings required on packaging to inform consumers of what the item is made from and how to responsibility dispose of it. Each EU member state can currently set its own rules. Such harmonisation would lead to a move away from the proliferation of different logos that are currently printed onto packaging in order to comply with the regulations of each country (see the article ‘The sustainability of packaging’.

iStock.com/joruba

The EU’s Packaging and Packaging Waste Regulation will set targets relating to increased recycled content

Taxation and accurate descriptions

In some ways, France been leading the way with sustainability legislation in recent years, and there are two initiatives from 2025 that are worth mentioning. The first is a proposed ‘Fast Fashion Tax’. This is intended to target companies which only sell online, have an extremely high rate of new product launches, and sell those products at extremely low prices.

The final criteria are still to be confirmed, but a tax would be charged on each item sold and the amount of tax would increase year-on-year. The proposed bill would also ban all advertising and influencer marketing linked to fast fashion. The funds raised through the tax are to be used to support France’s own sustainable fashion manufacturing sector.

The new French ‘Eco-Score’ or ‘French Environmental Cost’ Label has been launched. From 1st October 2025, brands can choose to voluntarily display an environmental score for their products. If they decide to do this, the score must be calculated using the Ecobalyse platform, or another tool that follows the same official methodology. From 1st October 2026, third parties such as non-governmental organisations (NGOs), retailers and consultants will be legally allowed to publish the environmental cost for a product if the brand itself has not already done so.

Finally, in Germany, the Higher Regional Court of Cologne ruled that the term ‘apple leather’ is misleading and cannot be used when a product does not contain any leather. This sets a precedent for other terms, such as ‘vegan leather’ and ‘synthetic leather’ that have commonly been seen in recent years. This action now aligns Germany with other countries, including Belgium, Italy, Portugal and Spain, where the use of the term ‘leather’ is already protected by law.

How can we help?

Please contact eco@satra.com for further information on sustainability-related legislation.

Publishing Data

This article was originally published on page 20 of the November 2025 issue of SATRA Bulletin.