Environmental compliance

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

Waste Framework Directive: Parliament adopts new EU rules on textiles
PPWR: Commission rules out postponement of obligations
Batteries Regulation: consultation on new methodology for calculating the collection target
CSRD and CSDDD: crunch time for Omnibus negotiations
Carbon Border Adjustment Mechanism: Parliament adopts simplification

Waste Framework Directive: Parliament adopts new EU rules on textiles

On 9 September 2025, the European Parliament gave its final approval to the revised Waste Framework Directive (WFD).

Following its publication in the Official Journal on 26 September, the Directive will now officially enter into force 20 days later, on 17 October 2025.

Member States then have 20 months to transpose the new provisions into national law.

Beyond the new binding food waste reduction targets, the Directive establishes extended producer responsibility (EPR) schemes for textiles, to be set up in all Member States within 30 months of entry into force.

Producers of clothing, footwear and household textiles will be responsible for covering the costs of collection, sorting and recycling.

The scope covers a wide range of products – from clothing and footwear to hats, blankets, bed and kitchen linen, and curtains. Member States may also extend the rules to include mattresses.

Importantly, the Directive allows for eco-modulated fees, enabling authorities to charge higher fees for less sustainable products, and to incentivise the use of recycled fibres in new products.

A long-awaited turning point

Every year, the EU generates around 12.6 million tonnes of textile waste. Less than 1% of textiles worldwide are currently recycled back into new textiles.

The Directive therefore underlines the importance of scaling up recycling and reuse infrastructure, particularly fibre-to-fibre recycling, to keep textiles in the loop and reduce Europe’s reliance on virgin raw materials.

For recycling and reuse operators, the long-awaited adoption of the Directive is a decisive signal: mandatory EPR for textiles across the EU will provide the financial certainty needed to expand infrastructure.

The European textile industry has faced growing pressure in recent years, with bankruptcies looming as companies struggle to operate in the absence of a harmonised framework.

The adoption of the new rules marks a long-awaited turning point, offering the stability and support needed for investment and innovation in textile recycling.

Deadlines and support

Member States must transpose the new WFD by June 2027 and establish functioning EPR schemes for textiles by April 2028. Micro-enterprises will have an additional year to comply. A first review of progress is scheduled for 2029.

Several Member States have already implemented EPR obligations for textiles and others have communicated draft legislation.

Landbell Group is helping producers to fulfill existing obligations and prepare for future ones.

To date, the Group has set up producer responsibility organisations in the Netherlands, Italy and Spain.

Its regulatory monitoring service also makes sure producers are aware of developments.

Find out more here.

PPWR: Commission rules out postponement of obligations

In recent weeks, calls had mounted across the EU, and particularly in Germany, for a delay to the start date of the Packaging and Packaging Waste Regulation (PPWR).

In a letter addressed to Environment Commissioner Roswall, industry associations and the German producer responsibility organisations (‘dual systems’) warned that applying the new producer definition in mid-2026 could cause major legal uncertainty, administrative complexity and even risks to the stability of the extended producer responsibility (EPR) system.

German Environment Minister Carsten Schneider publicly backed a postponement, suggesting that the obligations should only begin on 1 January 2027.

Obligations from mid-2026 as foreseen

The European Commission has now rejected these requests.

In letters addressed to both the dual systems and to members of the German Parliament (Bundestag), Environment Commissioner Roswall confirmed that the PPWR’s obligations will apply from mid-2026 as foreseen.

Roswall acknowledged that the mid-year start date could pose challenges, but emphasised that no Member State, MEP or stakeholder had raised this issue during the legislative process.

She underlined that the Commission is committed to a smooth and timely transition towards a more sustainable packaging sector.

While ruling out a formal postponement, Roswall indicated that her services are working on pragmatic solutions within the legal framework.

Specifically, the Commission is exploring ways to give Member States national leeway in 2026 to establish corrective mechanisms to account for the shift in responsibilities between obligated producers.

These discussions will take place with national authorities to ensure a coherent approach across the EU.

The Commission will continue consultations with Member States and stakeholders in the coming months to prepare for the August 2026 deadline.

For industry, this means preparations must proceed based on the current timeline, while awaiting further clarification on corrective mechanisms.

Batteries Regulation: consultation on new methodology for calculating the collection target

A crucial piece of the new Batteries Regulation is now taking shape.

On 17 September, experts from Oeko-Institut and Fraunhofer IZM presented their draft methodology for calculating how many waste batteries are available for collection (AfC).

This approach is designed to replace the current “available on the market” calculation methodology, which often fails to reflect real volumes of end-of-life batteries entering waste streams.

The proposed AfC framework seeks to reflect reality more closely by factoring in battery lifetimes and the flows where batteries are typically lost:

• in mixed municipal waste
• inside WEEE that is not fully depolluted, or
• when batteries are repurposed, remanufactured or embedded in second-hand products traded across borders

To fill gaps where data is scarce, the proposed model relies on default values – for example, four years for non-rechargeable portable batteries, nine years for rechargeable ones – from which Member States may only deviate if they provide robust and verified evidence.

At its core, the new system is bound by the principle of equivalent ambition: collection rates must not fall below what would have been achieved under today’s rules.

In practice, this means higher numerical targets will be needed to match the ambition of the current framework.

Stakeholders now have the chance to shape this methodology. Written input is invited by 15 October 2025, with questions ranging from the right way to calculate waste generated (three-year or five-year averages) to how hoarding, repurposing or cross-border trade should be accounted for.

A second workshop is planned for December to analyse the feedback received.

The Commission will then move towards a delegated act, due by August 2027, with the first reference year expected in 2028.

CSRD and CSDDD: crunch time for Omnibus negotiations

The European Parliament has entered the final stretch of negotiations on the sustainability Omnibus, which seeks to simplify and recalibrate the EU’s Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).

This legislative package is part of a broader drive to simplify EU rules and reduce burdens for business.

Parliament has now resumed negotiations on the file after the summer recess.

Since September, lawmakers have held three negotiating sessions to hammer out a compromise position, with two more scheduled before mid-October.

Sources describe the discussions as ‘tense’ and ‘intense’, reflecting deep divisions between political groups.

Scope remains an issue

One of the most contentious issues remains the scope of the rules.

Lead negotiator Jörgen Warborn (EPP, Sweden) has suggested separating the thresholds for CSRD and CSDDD.

Earlier this year, he floated the idea of applying both directives only to companies with more than 3,000 employees, limiting the scope to around 1,700 companies – far fewer than under the Commission’s proposal, which would have phased in CSRD for roughly 50,000 companies.

On the CSDDD, provisions on civil liability and climate transition plans are major sticking points.

The European People’s Party (EPP) has pressed other groups to prioritise one over the other, but progressive groups remain keen to keep both in the final text.

Next steps

Parliament’s agreement in October will be its official negotiating mandate for trilogues with the Council.

For businesses, this is the point where scope and obligations start to crystallise.

A narrower scope would exempt thousands of companies from detailed reporting and due diligence duties, while keeping broader requirements would mean more extensive compliance efforts across sectors.

The Legal Affairs Committee (JURI) is scheduled to vote on 13 October, followed by a plenary vote the week of 20 October.

If Parliament finalises its position, trilogues with the Council can begin before year-end.

However, timing remains tight, and further amendments are still possible up until the plenary stage.

Landbell Group’s sustainability report

For its forthcoming sustainability report, Landbell Group has decided to adopt the Voluntary Standard for non-listed micro-, small- and medium-sized undertakings (VSME).

Aligning with the VSME, which is published by the European Financial Reporting Advisory Group (EFRAG), helps the Group and its customers prepare for future requirements given the uncertainty around the CSRD and the European Sustainability Reporting Standards (ESRS).

Find out more about Landbell Group’s approach to sustainability, policies, commitments and recognitions here.

Carbon Border Adjustment Mechanism: Parliament adopts simplifications

On 10 September, the European Parliament approved changes to the EU Carbon Border Adjustment Mechanism (CBAM), aimed at reducing administrative burdens, particularly for SMEs and occasional importers.

A new 50-tonne de minimis threshold will exempt around 90% of importers from CBAM obligations, while still covering 99% of CO₂ emissions from iron, steel, aluminum, cement and fertiliser imports.

Safeguards and anti-abuse provisions will ensure environmental integrity remains intact.

Streamlined procedures for importers still covered include rules on authorisation, emissions calculation, verification and financial liability of CBAM declarants.

The amended law now awaits Council endorsement before entering into force.

CBAM itself will undergo a broader review in 2026, when the Commission will assess its extension to additional sectors.

Some progressive voices in the European Parliament are already starting to work on different ideas for scope expansion, with plastics and chemicals considered as possible options.