Environmental compliance

What are the latest developments? We’ve picked out some highlights for July 2025:

EU Simplification: two updates
Green Claims Directive: negotiations stall
Green Deal: PPWR secondary acts deprioritised
Now Available: authorised representative service for battery producers without a branch in Germany

EU Simplification: two updates

Battery Regulation due diligence delayed

The Council of the EU has endorsed a two-year delay to the due diligence obligations under the EU Battery Regulation.

These rules, originally set to apply from 18 August 2025, would then take effect on 18 August 2027, granting producers and exporters more time to adapt.

The European Parliament’s Environment Committee also recently approved the Commission’s proposal to delay the application of the new rules for batteries, to be followed by a final full plenary vote on 10 July.

If Parliament also approves the proposal, trilogue talks could follow shortly afterwards.

The delay, which is part of the Commission’s broader Omnibus IV package, aims to address industry concerns over the lack of accredited verification bodies and to streamline implementation.

Under the revised timeline, companies would only need to report on their due diligence compliance every three years rather than annually.

The Commission also plans to publish detailed implementation guidelines a year before the new rules take effect.

EU Waste Catalogue

In parallel, the updated EU Waste Catalogue with new waste codes for battery-related materials entered into force on 9 June 2025. The act introduces binding classification rules as of 9 November 2026.

These changes aim to improve traceability of hazardous fractions, such as lithium-based batteries and black mass, and will affect cross-border waste shipments, especially to non-OECD countries.

Higher thresholds for CSRD and CSDD proposed

Meanwhile, broader simplification efforts are still in flux.

MEP Jörgen Warborn, European Parliament rapporteur for the amendments to the Corporate Sustainable Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) has published his draft report on the text.

Warborn proposes to restrict reporting and due diligence rules to companies with more than 3,000 employees and €450 million in revenue, which would remove a substantial share of companies from scope.

This proposal is in line with the one made by Rapporteur Janusz Lewandowski, as reported in COMPASS last month here.

EU countries have also agreed the Council’s negotiating mandate on the file.

In the case of reporting, this includes an employee threshold of 1,000 (in line with the Commission’s original proposal), but a net turnover threshold of over €450 million (whereas the Commission proposal was a net turnover threshold of €50 million).

Regarding due diligence obligations, EU countries go even further, increasing thresholds to 5,000 employees and net turnover to €1.5 billion.

Green Claims Directive: negotiations stall

The legislative process for the EU’s Green Claims Directive – intended to combat greenwashing – has come to a standstill following a sudden breakdown in negotiations between the European Commission, Council and Parliament.

Initially proposed in March 2023, the Directive aims to introduce detailed requirements obliging companies to substantiate environmental marketing claims, such as “climate neutral” or “recyclable”, through independently verified evidence.

Its objective was to prevent misleading practices and create a level playing field for businesses making credible sustainability claims.

On 21 June 2025, just days before final talks were set to conclude, the European Commission unexpectedly announced it intended to withdraw the proposal.

This followed criticism that the directive was overly complex and burdensome for businesses, especially smaller companies.

The Polish Council Presidency, citing the Commission’s unclear position, cancelled the trilogue negotiations scheduled for 24 June.

The European Parliament, which had not agreed to stop the talks, strongly criticised the move, with Parliament’s co-rapporteurs and committee chairs expressing concern that the move undermined two years of negotiations and parliamentary work, and warned it could set a dangerous precedent for the legislative process.

Adding to the confusion, the Commission issued conflicting statements in the days that followed, when a senior Commission official said President von der Leyen still supported the directive and that the Commission had not officially withdrawn it.

According to the official, the Commission only raised concerns because Member States were trying to include very small businesses (with fewer than 10 employees) in the scope, which was not part of the original plan.

Nonetheless, momentum has stalled.

Following Italy’s formal withdrawal of support for the file, the Council no longer holds the necessary majority, making it impossible to continue with the file under current conditions.

Member states are now expected to discuss the matter further in July.

Green Deal: PPWR secondary acts deprioritised

As part of a broader push to simplify EU regulation, the European Commission has scaled back its ambitions for secondary legislation under the Green Deal.

In April 2025, Environment Commissioner Jessika Roswall announced a plan to reduce by one third the number of delegated and implementing acts in the environmental field, defining the detailed rules necessary to put into operation primary EU legislation.

Internal lists shared with the European Parliament on 24 April and 23 May reveal the concrete outcome of this effort.

Nearly 200 delegated and implementing acts remain classified as “priority” by the Commission’s services.

However, around 60 texts have been designated as “non-priority” and will no longer be actively pursued.

The Packaging and Packaging Waste Regulation (PPWR) is affected.

A dozen of the regulation’s planned secondary acts remain on the priority list, including:

rules for extended producer responsibility (EPR) registration (Q1 2026)
harmonised labelling (Q3 2026), and
calculating recycled content (Q4 2026)

Three PPWR acts have been deprioritised:

an implementing act on digital labelling to help sort packaging waste
a delegated act on pooling systems for reusable beverage packaging, and
an implementing act on mandatory green criteria for public procurement

Also deprioritised are several secondary measures linked to the EU Battery Regulation, Electrical and Electronic Waste & Restriction of Hazardous Substances via the RoHS Directive, as well as waste shipments and international waste management.

While the Commission has not explicitly said that these acts will be abandoned, it has opened the door to amending or removing the legal obligation to adopt some of them, particularly where a binding deadline exists.