We have updated our ESG timeline to provide an overview of ESG developments in the UK and EU in 2026. A number of recent and upcoming developments seek to support the transition to a circular economy by making products and supply chains more sustainable, focusing on aspects such as recyclability, durability and repairability. This blog spotlights some of these developments, along with key dates to be aware of.
EU Packaging and Packaging Waste Regulation (“PPWR”)
 | What: The PPWR replaces the former EU Packaging Waste Directive and is designed to harmonise national packaging regimes across the EU. It applies to all packaging and packaging waste. It sets requirements for manufacturing, composition, reusability, recoverability, waste management and prevention. |
 | When: The PPWR came into effect on 12 August 2026, with certain obligations taking effect at a later date. |
 | Who: Compliance with the PPWR should be considered by anyone seeking to sell packaging or packaged products in the EU. |
EU Ecodesign for Sustainable Products Regulation (“ESPR”)
| What: The ESPR aims to improve the circularity, energy performance, recyclability and durability of products to improve their overall sustainability. The ESPR introduces “ecodesign requirements” including increased recycled content and addressing the presence of substances that inhibit circularity. It also introduces a requirement for a Digital Product Passport (“DPP”) as part of the information requirements. |
| When: The ESPR came into force on 18 July 2024. In July 2026, the ESPR’s ban on the destruction of unsold textiles and footwear began to apply to large companies, with the ban applying to medium-sized enterprises from 19 July 2030. Other measures targeting aluminium, textiles and apparel, tyres, and repairability of products are expected to come into force throughout 2027. A DPP registry was launched on 20 July 2026. |
| Who: Compliance with the ESPR should be considered by anyone placing non-exempt physical goods on the market in the EU, or putting them into service. |
EU Batteries Regulation
| What: The Batteries Regulation aims to make batteries sustainable throughout their entire lifecycle. It covers all batteries that are placed on the EU market, regardless of where they are manufactured. This includes electric vehicle batteries, batteries for consumer goods, and batteries for electric bikes and scooters, amongst others. Obligations include a due diligence obligation for companies to identify, prevent and address social and environmental risks linked to certain raw materials in batteries. |
| When: The Batteries Regulation came into force in August 2023. The European Commission adopted a delegated act on 14 July 2026 to exempt further products from the requirements on removability and replaceability of portable batteries, including wearable devices, electric toys, and equipment used in explosive atmospheres. The due diligence requirements under the Batteries Regulation will apply from 18 August 2027, following a two year postponement. |
| Who: The Batteries Regulation applies to all “economic operators” involved in placing batteries on the EU market or putting them into service, including manufacturers, importers and distributors. |
EU Regulation on Deforestation-free Products (“EUDR”)
| What: The EUDR aims to boost the consumption of “deforestation-free” products and reduce the EU’s impact on global deforestation and forest degradation. The EUDR covers cattle, cocoa, coffee, palm oil, rubber, soy and wood and certain derived products. Companies importing or exporting these commodities into or out of the EU will have to prove that the products are free from deforestation. |
| When: Large and medium operators, downstream operators and traders will have to comply with the EUDR from 30 December 2026, whilst micro and small enterprises will need to comply from 30 June 2027. |
| Who: The EUDR creates obligations for operators, including downstream operators, and traders who make in-scope commodities available on the EU market or export them from the EU. |
UK Forest Risk Commodities Regime
| What: The UK government intends to strengthen its approach to tackling deforestation by introducing regulations that will require businesses using forest risk commodities and wood products to carry out due diligence to ensure these are produced in compliance with relevant local laws. These requirements are intended to apply to wood, cattle, cocoa, coffee, palm oil, rubber, soy and certain derived products like chocolate and furniture. |
| When: Not yet in force. The government plans to launch a consultation later in 2026, with legislation expected to be implemented in 2027. |
| Who: Businesses in Great Britain with an annual turnover of over £1 million that use in-scope commodities. |
EU Right to Repair Directive
| What: The Right to Repair Directive seeks to address the problem of repairable defective goods being prematurely discarded by incentivising consumers to choose repair over replacement. Manufacturers must repair certain products (including washing machines, dishwashers, mobile phones, electronic displays and vacuum cleaners) if the consumer requests the repair, unless it is impossible to do so. |
| When: EU Member States were required to apply the Right the Repair Directive from 31 July 2026. Manufacturers’ obligations have applied from that date regardless of when goods were sold. The Commission also plans to establish an online repair platform, to allow consumers to find repairers, and will develop the online interface for the platform by 31 July 2027. |
| Who: The obligations primarily affect manufacturers and, where applicable, authorised representatives, importers and distributors, and there are also obligations for sellers and repairers. Manufacturers and sellers based outside of the EU are affected if they sell goods that are subject to repairability requirements within the EU. Manufacturers’ authorised representatives (or, if there isn’t one, their importer or distributor) will be responsible for repairing goods. |
EU Empowering Consumers for the Green Transition Directive
| What: The Empowering Consumers for the Green Transition Directive, which amends the Unfair Commercial Practices Directive and the Consumer Rights Directive, will, amongst other things, require traders to provide consumers with pre-contract sustainability information including on the durability and repairability of goods, and increase consumer protection against unfair commercial practices that prevent sustainable consumption choices such as greenwashing. |
| When: Member States are required to apply the Directive by 27 September 2026. |
| Who: The requirements will primarily apply to traders engaging in business-to-consumer commercial practices targeting EU consumers, and could therefore have implications for non-EU traders. |
EU Forced Labour Regulation (“FLR”)
| What: The EU FLR aims to ensure that products made with forced labour are not sold on or exported from the EU market. Products found to be made with forced labour will be banned and non-compliant producers can be fined. |
| When: The substantive provisions become applicable on 14 December 2027. |
| Who: The FLR applies to any natural or legal person, whether based in the EU or not, who seeks to place or make available a product on the EU market, or export a product from the EU. |
Key dates from our timeline
23 June 2026
The UK government published a policy paper on its approach to deforestation regulations. The government will launch a consultation later in 2026, with legislation expected to be implemented in 2027.
26 June 2026
(EU) The European Commission published its guidelines on the application of the FLR. The guidelines are not legally binding, but are intended to supplement the FLR. The guidelines were subsequently published in the Official Journal of the EU on 3 September 2026.
13 July 2026
(EU) The European Commission adopted secondary legislation to simplify the EUDR, including updating and simplifying the list of products subject to the EUDR and operational simplifications. Cattle hides, skins and leather, re-treaded tyres, soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft and motor vehicle seats have been removed from scope, and soluble coffee, certain palm oil derivatives and frozen cattle tongues have been added. The main EUDR guidance has been updated to reflect the changes.
14 July 2026
(EU) The European Commission adopted a delegated regulation under the Batteries Regulation introducing new rules that exempt additional products from EU requirements on the removability and replaceability of portable batteries, including wearable devices, electric toys and products within the scope of the ATEX Directive (equipment used in explosive atmospheres). The scrutiny period is three months from notification, with a possible two month extension. It will enter into force 20 days after its publication in the Official Journal of the EU, provided there are no objections.
19 July 2026
(EU) The ESPR ban on the destruction of unsold textiles and footwear began to apply to large companies. It applies to medium-sized enterprises from 19 July 2030.
20 July 2026
(EU) The European Commission launched the DPP Registry. Forming part of the ESPR, it is a digital repository of product information designed to strengthen supply chain transparency. The first implementation deadline for mandatory digital passports is 18 February 2027 for certain types of large batteries.
31 July 2026
(EU) Deadline for Member States to transpose the Right to Repair Directive into national law.
3 August 2026
(EU) The European Commission published updated FAQs on the PPWR.
12 August 2026
(EU) The EU PPWR began to apply. Guidance was published in the Official Journal of the EU on 10 June 2026.
27 September 2026
(EU) Deadline for Member States to apply the Empowering Consumers for the Green Transition Directive.
Q3 2026
(EU) The European Commission is expected to publish its proposal for a Circular Economy Act. The UK government has yet to publish its Circular Economy Growth Plan.
30 December 2026
(EU) EUDR obligations begin to apply to large and medium operators and traders (with micro and small enterprises to comply with the rules from 30 June 2027).
This blog is a high level summary and is necessarily not comprehensive. For key developments in other areas of ESG regulation, please see our ESG timeline.
/Passle/620e2412f636e9042828e117/SearchServiceImages/2026-09-16-09-34-00-080-6aaa62884c0adca8a36cc07b.jpg)
/Passle/620e2412f636e9042828e117/SearchServiceImages/2026-09-15-10-50-26-055-6aa922f2c429248dfcf9d775.jpg)
/Passle/620e2412f636e9042828e117/SearchServiceImages/2026-09-09-08-28-25-403-6aa118a9414b094d694cc8eb.jpg)
/Passle/620e2412f636e9042828e117/SearchServiceImages/2026-08-28-14-17-11-332-6a9198677a2ddcfc00f20f66.jpg)