Extended Producer Responsibility (EPR) is no longer just a waste management policy — it’s a design mandate. Across Europe, new EPR regulations are forcing a shift in how businesses think about packaging, moving responsibility upstream to the earliest stages of product development. In this new landscape, lifecycle thinking isn’t optional — it’s operational.
Why EPR is a Gamechanger for Packaging
Traditionally, the environmental impact of packaging was managed at the end of its life — collected, sorted, and (hopefully) recycled. EPR turns that model on its head. By making producers financially and legally responsible for the full lifecycle of their packaging, the EU aims to drastically reduce waste and increase resource efficiency.
Under the proposed Packaging and Packaging Waste Regulation (PPWR), packaging that cannot be reused or recycled will be restricted from the EU market by 2030 (European Commission, 2022). This includes new design-for-recyclability requirements, reuse targets, and volume reduction rules — all linked directly to EPR compliance and cost.
Here’s how this EU legislation is changing packaging design
Easy waste management first:
Packaging must be recyclable in practice and at scale by 2030, according to the PPWR, though rates vary by category.
This is pushing a shift away from complex, multi-layer materials toward mono-materials like PE, PP, and PET and packaging will require labelling with materials and waste management instructions.
There is a move away from dark-colored plastics that disrupt sorting systems.
Other packaging types, such as filter coffee pods, must be compostable by early 2027.
Reuse in rising:
The PPWR introduces binding reuse targets for food and beverage packaging — 10% to 20% by 2030 in many cases, but excluding certain materials such as cardboard.
This change is driving innovation in reusable formats and return logistics, especially in takeaway and catering.
Less is more:
Packaging must now minimize empty space (no more than 40% of volume) and reduce material weight. Likewise, there is a maximum 50% empty space ratio for grouped, transport, and e-commerce packaging.
Companies are redesigning formats to optimize efficiency — less space, less waste, lower fees.
Packaging misleading consumers into thinking the product is larger than it actually will be banned (e.g. double walls, false bottoms).
What this means for brands (and suppliers)
For packaging producers and their clients, this shift is both a challenge and a chance. Non-compliant packaging will face higher costs — or be removed from the market altogether. But proactive design can:
Lower EPR fees
Improve ESG scores
Meet consumer expectations for sustainability
Avoid regulatory and reputational risks
And for suppliers? Those who support their clients in achieving compliance — through smarter design, sustainable materials, and transparent reporting — will be invaluable partners.
Sustainable e-commerce is more than just a trend – it’s a response to modern customer expectations and evolving market challenges. This article outlines step-by-step how to embed ESG principles into your online store. You’ll discover how to improve operational efficiency, reduce environmental impact, increase customer loyalty, and leverage responsibility as a genuine competitive advantage.
ESG implementation in e-commerce – a practical guide for businesses
A well-planned ESG strategy helps build a resilient and trusted e-commerce business. More importantly, it can have a direct, positive impact on financial performance.
What is ESG and Why Should It Matter in E-Commerce?
ESG stands for Environmental, Social, and Governance – a set of practices designed to foster environmental responsibility, social accountability, and corporate governance integrity.
When implemented effectively, ESG not only demonstrates responsibility but also enhances competitiveness, mitigates risk, and builds stronger customer loyalty.
Sustainable logistics and distribution in e-commerce – practical actions
Optimizing distribution is one of the most effective ways to reduce your online store’s carbon footprint.
How can you make deliveries more environmentally friendly?
Use electric delivery vehicles, especially in urban areas and for short distances.
Partner with local suppliers to shorten the supply chain and reduce emissions.
Implement renewable energy sources in logistics centers and offices.
Plan delivery routes smartly using process optimization tools.
Decarbonize your supply chains gradually, introducing changes in phases.
Let’s talk!
Our advisors can help you identify major emission points and design an ESG-compliant logistics strategy.
Eco-friendly packaging and storage for online retailers
Sustainable packaging and efficient warehousing are key to reducing waste and improving operational performance.
What changes should you consider in packaging and warehousing?
Ship products in recyclable, eco-friendly packaging.
Use reusable packaging where applicable.
Communicate your eco-efforts to customers starting from the moment they open their package.
Optimize energy usage in warehouses by introducing green energy solutions.
Manage your digital footprint using green hosting and energy-efficient servers.
We’ll help you select and implement ESG-aligned solutions that benefit both your business and the planet.
Designing ESG-compliant offers and reducing return rates
Product offering and customer communication are central to responsible and successful e-commerce.
What can you do to align your product offer with ESG standards?
Provide detailed product descriptions, including composition, origin, and usage guidelines.
Include high-quality images and videos to minimize purchase errors.
Introduce product fitting tools like virtual try-ons or AR visualizations.
Design products based on customer needs and shopping behavior analytics.
Clearly label environmentally and socially responsible products to support value-based purchasing.
Promote circular economy initiatives through repair, return, or recycling programs.
We offer support in ethical product design, ESG-compliant customer communication, and regulatory alignment.
Communication, cybersecurity, and governance – ESG in daily operations
Responsibility also means how you manage your company and protect customer data.
What should you prioritize to run a responsible e-commerce business?
Ensure transparent communication – transparency is a value in itself.
Safeguard customer privacy with high cybersecurity standards.
Develop ethical governance principles that shape your organizational culture.
Maintain responsible labor practices – both internally and across your supply chain.
Monitor and report ESG efforts transparently and in accordance with current standards.
With our support, you can automate ESG reporting and implement a management system tailored to your company’s structure.
Summary: ESG is an investment in the future of your business
Sustainable e-commerce is not a passing fad – it’s a strategic response to consumer expectations, regulatory requirements, and increasing competition. It’s also an opportunity to build a strong, resilient, and trusted brand.
Looking to cut emissions and optimize your distribution?
Searching for eco-friendly packaging solutions and smarter warehouse management?
Need help aligning your offer with your customers’ values?
Our experts support you across all areas – from analysis and implementation to regulatory compliance. We tailor solutions to your organization’s structure and strategy. We don’t just help you “comply” – we help you gain a real advantage.
Sustainable growth begins with a decision. If you want your store to operate responsibly, efficiently, and with the future in mind – we’re here to support you.
In February, the EU announced its groundbreaking Omnibus proposal, aiming to simplify non-financial reporting frameworks. One of the most impactful proposals in this announcement was the severely limited scope of the companies required to report under the CSRD.
VSME vs ESRS
While policymakers debate the details of the Omnibus in the coming months, many companies – particularly those between the old scope and the new scope – are left confused as to the future of their sustainability reporting.
One option for companies is the Voluntary Small and Medium Enterprise standard (VSME), which employs the core elements of the European Sustainability Reporting Standards (ESRS) and other common non-financial reporting standards in a more accessible and simplified way. Companies have the option to take the Basic (B) route or the more Comprehensive (C) route. For example, the ESRS 1&2 can either be the B1–B2 (Basic), C1–C2 (Comprehensive).
The graphic below depicts how the ESRS topical standards translate into the VSME:
Source: “VSME vs ESRS: Understanding the key differences in sustainability reporting”
As you can see, many of the key areas from ESRS are still addressed in the VSME, just in more simplified ways and often with a smaller scope.
What about the Double Materiality Assessment (DMA)?
While the VSME does not require a formal DMA as the ESRS does, it does apply a “if applicable” principle, where companies are recommended to report only on those topics that are relevant to their operations and stakeholders.
Thus, while an extensive and audited DMA is not mandatory, doing even a simplified assessment can be beneficial to SMEs in multiple ways:
Identifying relevant disclosures
Prioritising sustainability efforts and resources and, in the process, strengthening a sustainability strategy
Laying the groundwork for future CSRD work, where it is required
Why should SMEs report on sustainability?
Companies considering pursuing sustainability reporting, even if they are not obliged to do so by European regulation, should understand six key benefits of increasing data collection and transparency in this area:
Standardising ESG data requests from larger partners, customers, and other stakeholders as having already gathered this data will make responding to such requests easier and more automatic
Pinpointing areas for improvement to increase resource efficiency leading to savings in water, energy, materials, labour, etc. – and thus resulting in financial savings as well
Identifying risks across the supply chain
Gaining competitive advantage in green financing opportunities – more information available in the recent EU Platform on Sustainable Finance report “Streamlining Sustainable Finance for SMEs” released in March 2025)
Building transparency, and thus reputation, with consumers, partners, and other stakeholders
Setting yourself up for success in future growth, especially given that the VSME and ESRS contain many of the same elements
VSME vs LSME
It is also important to note that some Small and Medium Enterprises (SMEs) – those that are publicly listed – may have some mandatory reporting elements. These were included in the Listed SME standard, or LSME, but the recent Omnibus proposal abolished these requirements, so the future of LSME reporting is unclear. Policymakers and experts are debating which standard, the Voluntary SME standard (VSME) or the Listed SME standard (LSME), is better and how to streamline these further to limit confusion between the two non-CSRD alternatives, particularly given that, as discussed, above, the VSME also has a Basic and Comprehensive version.
Conclusion
Despite the cutbacks in the scope of required CSRD reporting, companies that fall outside this obligation can still gain substantial value from adopting the VSME. Its strong alignment with the ESRS framework means that companies voluntarily following VSME not only stay ahead of potential future requirements but also build a solid foundation for strategic sustainability management. Whether for stakeholder transparency, operational efficiency, or long-term resilience, engaging with VSME reporting is a smart step forward.
Bulgaria is advancing its tax compliance framework by implementing the Standard Audit File for Tax (SAF-T), an OECD-developed international standard for electronic data exchange between taxpayers and tax authorities. This initiative aims to enhance transparency, streamline auditing processes, and facilitate more efficient tax compliance.
Implementation timeline
The SAF-T rollout in Bulgaria is planned in phases:
2026: Large enterprises (annual turnover over BGN 300 million or tax liabilities exceeding BGN 3.5 million) will commence reporting.
2028: Mid-sized enterprises (annual turnover over BGN 15 million or tax liabilities exceeding BGN 1.5 million) will be included.
2030: All other taxpayers, including micro-enterprises, will be required to comply.
This phased approach allows businesses sufficient time to adapt to the new requirements.
Benefits of SAF-T implementation
The adoption of SAF-T is expected to:
Enhance Fiscal Risk Management: Standardized data facilitates better detection and management of fiscal risks.
Reduce Administrative Burden: Automation of data submission simplifies compliance processes for businesses.
Promote Compliance: Clear guidelines and standardized reporting encourage adherence to tax regulations.
Preparing for the transition
Business owners are encouraged to prepare for the SAF-T transition by consulting with tax professionals or digital accounting solution providers. Early preparation will facilitate a smoother adaptation to the standardized reporting requirements and ensure compliance with the new system.
On March 11, 2025, following extensive negotiations, consultations, and legislative work, the Council of the European Union officially adopted the “VAT in the Digital Age” (ViDA) package, introducing sweeping reforms to the EU VAT system. As a result, amendments to the EU VAT Directive and associated regulations will be required. Implementing regulations will take effect 20 days after their publication in the Official Journal of the European Union and will apply automatically. However, for the VAT Directive amendments to be effective, each Member State must transpose them into its national legal framework.
Three core pillars that the ViDA reform is built on
Single EU-Wide VAT Registration
By 2028, the reverse charge mechanism under Article 194 of the EU VAT Directive will be significantly extended. This will apply to the supply of goods and services by vendors without a fixed establishment or place of business in the destination Member State, provided the recipient is VAT-registered in that country.
In the same year, the scope of the One Stop Shop (OSS) scheme will be expanded to include intra-EU movements of own goods and all B2C sales conducted across borders.
E-Invoicing and VAT Reporting Requirements
From the outset of ViDA’s implementation, Member States will be allowed to introduce mandatory e-invoicing. While many countries have already adopted or are in the process of implementing such systems, ViDA will harmonize this practice EU-wide. Under the reform, electronic invoices will become the only legally recognized format, replacing paper invoices.
By 2030, e-invoicing will be compulsory for cross-border transactions within the EU. Digital Reporting Requirements (DRR) will be introduced for intra-Community B2B transactions, replacing the current European Community Sales List (ECSL).
Businesses will be required to issue an e-invoice within two days of the VAT liability arising and to transmit it to the national e-invoicing system within the same timeframe.
By 2035, existing national digital reporting frameworks must be aligned with ViDA standards. Countries with established systems (e.g. Italy, France, Poland, Germany, Romania, and Belgium) will need to ensure compliance by the deadline.
VAT Compliance Obligations for Digital Platforms
From 2030, new reporting obligations will apply to digital platforms.
Currently, platforms facilitating the sale of goods are treated as deemed suppliers. Under ViDA, this deemed supplier status will be extended to platforms offering short-term accommodation and passenger transport services, as well as B2B intra-EU transactions facilitated through their systems.
The European Commission formally launched the ViDA reform on December 8, 2022. This initiated a series of negotiations within the Council and European Parliament to establish a modernized regulatory framework for VAT, tax compliance, and cross-border operations within the internal market.
ViDA responds to ongoing challenges faced by Member States, including a persistently high VAT gap, fraudulent business practices, and VAT fraud networks exploiting legal loopholes and systemic inefficiencies.
Key objectives of the ViDA package include:
Implementing mandatory e-invoicing and real-time reporting to reduce VAT fraud and enhance data sharing between tax authorities.
Expanding the OSS scheme to cover B2B transactions, minimizing the need for multiple VAT registrations across Member States.
Enhancing data exchange and increasing VAT compliance responsibilities for digital platforms, particularly those in short-term rental and passenger transport sectors.
Promoting full digitization of VAT processes to streamline cross-border business operations and improve audit efficiency.
Harmonizing technical and legal requirements across the EU to reduce discrepancies in national invoicing and reporting systems.
Who Will Be Affected?
The primary stakeholders include companies conducting B2B and B2C sales across the EU—whether already using the OSS or providing goods/services in multiple Member States.
Digital platforms, especially those involved in short-term rentals and transport services, will face new VAT collection and reporting obligations on behalf of their users.
All VAT-registered businesses, regardless of whether they currently use traditional or electronic invoicing systems, will be gradually required to adopt e-invoicing and real-time reporting in accordance with the new regulations.
ViDA will have a direct impact on both B2B and B2C transaction models:
B2B Transactions – mandatory e-invoicing and real-time reporting will transform the invoicing process between businesses. The OSS scheme will be extended to B2B transactions, facilitating VAT compliance and reducing the need for multiple registrations across jurisdictions.
B2C Transactions -planned changes will further simplify the OSS (and IOSS for low-value imported goods), significantly reducing administrative burdens and the number of declarations submitted across various Member States. Additional changes are anticipated in how VAT is collected and reported for cross-border consumer services.
Implications for VAT Registration, Declarations, ECSL, and Intrastat
VAT Registration – The expanded OSS will allow more international transactions to be reported under a single VAT number, minimizing the need for multi-country VAT registrations.
VAT Declarations– Real-time reporting and e-invoicing will standardize how and when data is submitted to tax authorities. Member States will implement systems akin to Poland’s KSeF or Italy’s SdI.
ECSL and Intrastat – Eventually, data currently reported via ECSL and Intrastat will be sourced automatically through e-invoicing and real-time reporting systems. These obligations will be phased out in favor of integrated OSS VAT reporting.
Since the Omnibus proposal was announced on February 26th, consulting firms and non-profits have debated its impact—not just on reporting companies (as we discussed here) but also on the efficacy of the EU’s Green Deal and its broader sustainability ambitions.
On ‘Omnibus’ Proposal’s impact
Julia Otten, Senior Policy Officer at the consulting firm Frank Bold, criticized the proposed changes to the Corporate Sustainability Due Diligence Directive (CSDDD), arguing:
Julia Otten, Senior Policy Officer at the consulting firm Frank Bold, criticized the proposed changes to the Corporate Sustainability Due Diligence Directive (CSDDD), arguing:
The proposed changes… would effectively dismantle the law before it’s even started to apply, without presenting any proper evidence. Addressing crucial issues like child labour and forced labour requires targeted oversight beyond direct business partners in the value chain. It is absurd that the Commission is proposing to limit this. The sudden shift appears to prioritise short-term industry pressures over long-term sustainability goals and the protection of human rights.
Others echo this concern.Richard Gardiner, Strategic Public Policy Lead of the World Benchmarking Alliance, warned that removing the requirement in Article 22 of the CSDDD to “put into effect” climate transition plans could undermine climate action:
This goes completely against that intention [of other EU policies to effect a decarbonised economy] and worst-case scenario could reduce these plans to kind of a paper exercise, a publicity exercise, but something that doesn’t have any real effect on how the company functions.
Similarly, Mariana Ferreira of WWF described policy changes to the EU Taxonomy as a “significant butchering” of the framework. While the revised taxonomy still covers major corporations, the reduction in scope and materiality thresholds for reporting weakens its effectiveness, she argued.
Such omissions reduce accountability and hinder firms, investors, and stakeholders from assessing whether climate policies achieve their intended impact due to diminished availability of comparable data. While the proposal’s focus on quantitative disclosures may improve some comparisons, many climate advocates, regulators, and investors stress that climate risks are financial risks—making robust reporting essential for economic stability.
The legislative process for this proposal is far from final. Experts predict that the most urgent element—the so-called “stop the clock” provision—may not be finalized until Q3 of this year, ensuring a lengthy and contentious debate. Positions vary across the EU: while countries like France, Germany, and Poland are expected to support the simplifications, others, including Spain and Italy, argue that the proposed changes are too extreme, according to Tony Christensen, Director of Position Green.
As negotiations continue, sustainability professionals across Europe will be closely watching how the Omnibus proposal evolves and what it means for the future of the EU’s sustainability strategy.
Although the European Union (EU) has established Extended Producer Responsibility (EPR) policies through legislation like the Directive on Waste Electrical and Electronic Equipment and the Directive on Packaging and Packaging Waste, the implementation of these policies can still vary significantly across member states and is continually evolving. Since the Omnibus proposal was announced on February 26th, consulting firms and non-profits have debated its impact—not just on reporting companies (as we discussed here) but also on the efficacy of the EU’s Green Deal and its broader sustainability ambitions.
On EPR overview internationally
While EPR policies share a common goal—shifting the responsibility of waste management from consumers and governments to producers—their implementation varies widely across regions. Some countries enforce strict, centralized regulations with heavy penalties for non-compliance (e.g., South Korea), while others take a decentralized approach with state- or province-level policies (e.g., the US and Canada). Additionally, some frameworks emphasize financial contributions from producers, while others focus on physical take-back schemes or circular economy incentives. Understanding these variations is crucial for businesses operating in multiple markets, as compliance requirements, reporting obligations, and financial burdens differ significantly.
In this article, we will explore EPR frameworks beyond the EU, offering a broad overview of how some of the world’s largest economies are adopting and adapting similar principles in diverse ways.
Country Overviews
Key product categories
Key compliance factors
United States (US)
Packaging, electronics, pharmaceuticals…
State-level EPR laws enacted in states like Maine, Oregon, Colorado, California, and Maine, with others in development, focussing on packaging. No national policy and none expected under the Trump administration.
Canada
Packaging, electronics, batteries, tyres…
Province-level EPR laws enacted in British Columbia, Yukon, Alberta, Saskatchewan, Manitoba, Ontario, Québec, New Brunswick, and Nova Scotia. A Federal Plastics Registry on its way.
Brazil’s pioneering 2010 credit policy has recently been updated in 2022 to enhance enforcement and circularity where it has been lacking. Reverse logistics certificates as well as engaging the informal waste picking sector play a key role in monitoring and compliance.
Largely organised at a state and local level, but Mexico’s new government has proposed expansions to circularity and recycling targets (e.g., for electronics) but feasibility and enforceability of these plans is debated.
China
Packaging, electronics, batteries…
Electronics and battery producers are tasked with waste management, implementing more eco-design, and transparency. EPR implementation for packaging expected to be added to this legislation in 2025.
Japan
Packaging, electronics, vehicles, appliances…
Some form of EPR in place since the 1990s, making it the first in Asia, with most of the focus on bottles and other packaging. Specific laws, created in the 1990s and 2000s, dictate each product type, from vehicles to appliances.
South Korea
Packaging, batteries, tyres, lubricants…
The system is managed centrally, unlike some countries, where it is done by industry, but companies can choose to manage it themselves. High financial penalties for non-compliance, much greater than the cost of recycling.
India
Plastic, batteries, electronics, tyres…
Separate laws govern different product types, but all require registration with the Central Pollution Control Board (CPCB). Often implemented by the informal waste management sector.
Australia
Packaging, electronics, batteries, tyres…
Much of the waste is managed by voluntary and mandatory “product stewardship schemes” at the federal and regional levels, but some categories, such as tyres and mobile phones are led by the industries themselves.
South Africa
Packaging
2020 legislation requires producers of paper and plastic packaging to integrate EPR principles. Registration with the Department of Forests, Fisheries, and the Environment or, later, the Waste Information Centre, is mandatory.
As illustrated in the table above, EPR strategies and their scope differ significantly across countries, even among those that have implemented these policies for many years. In some nations, EPR is managed at the federal level, while in others, it is handled regionally. The responsibility for these programs also varies—some are led by governments, others by industries, and in many cases, they involve coalitions of multiple stakeholders. The primary areas of focus are typically packaging and single-use plastics, with an increasing emphasis on electronic waste as its generation continues to rise.
Do you want your company to stay ahead of the changes?
Looking ahead, EPR policies are expected to become more stringent, with increased reporting requirements, stricter eco-design mandates, and broader product coverage. Many jurisdictions are expanding EPR frameworks to include textiles, furniture, and other durable goods, in addition to traditional categories like packaging and electronics. Transparency will also be a growing focus, with digital tracking systems and producer responsibility databases (e.g., Canada’s Federal Plastics Registry) becoming more common.
Given the dynamic nature of Extended Producer Responsibility (EPR) frameworks worldwide, it is clear that these systems are continually evolving in response to shifting environmental, economic, and regulatory landscapes. As such, stakeholders must remain agile and attentive to emerging trends and policy developments in order to effectively navigate the changing global landscape of EPR.
To stay ahead of evolving EPR requirements, companies should:
Monitor Regulatory Developments: EPR rules are constantly changing, and keeping track of new regulations at national, regional, and international levels is essential.
Improve Product Design: Investing in eco-design, recyclability, and material reduction can help companies lower compliance costs and align with future regulations.
Engage in Industry Partnerships: Many successful EPR programs are led by industry coalitions. Companies should explore partnerships with Producer Responsibility Organizations (PROs) and other stakeholders to share compliance burdens.
Enhance Transparency and Reporting: With digital compliance tracking becoming a priority, businesses should establish robust data collection and reporting mechanisms to ensure they meet regulatory requirements.
As global EPR policies continue to evolve, businesses that take a proactive approach will be better positioned to navigate regulatory challenges, reduce environmental impact, and strengthen their brand reputation in a sustainability-driven market. Keeping a close eye on legislative changes and emerging best practices will be key to long-term success in the circular economy.
– “Extended Producer Responsibility in Mexico: A Human Rights Perspective” by Adalberto Méndez (Jun 2023) for the International Alliance of Waste Pickers and WIEGO mexico-epr_IAWP_english.pdf
China:
– “China: Existing Regulations Related to Extended Producer Responsibility (EPR)” by Regional Knowledge for Marine Plastic Debris (2024) Extended Producer Responsibility | RKC-MPD
– “Product Stewardship” by the Australian Government Department of Climate Change, Energy, the Environment and Water (2013) Product stewardship – DCCEEW
The European Commission’s proposals to simplify ESG regulations as part of the so-called Omnibus Package published on February 26th 2025 have sparked a wide debate on their impact on the functioning of companies. The main objective of the changes is to reduce the administrative burden on enterprises and improve their competitiveness. However, there is a risk that reducing ESG reporting obligations could lead to a loss of availability of key ESG data for investors in the long term and difficulties in monitoring sustainability progress.
ESG deregulation – intentions and consequences
Both legislative packages – Omnibus I and Omnibus II – are aimed at simplifying the requirements for companies, especially in the field of the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDD). The key assumption is to reduce administrative obligations by about 80%.
The new regulations will apply only to the largest enterprises which:
employ over 1000 employees
and generate annual revenues exceeding EUR 50 million and/or having a balance sheet total of more than EUR 25 million.
All other companies will be able to report voluntarily (using the VSME standard), which will ultimately be issued in the form of a delegated regulation.
The reporting schedule has also been changed. Companies that were supposed to publish a sustainability report for the first time in 2026 or 2027 will be given additional two years to adapt to the new requirements.
In addition, sector-specific reporting standards have been removed, meaning that companies will not have to adapt reports to industry-specific guidelines.
The Omnibus package also provides for the simplification of reporting in the field of:
EU Taxonomy – Disclosures regarding the Taxonomy will be mandatory only for companies that both have more than 1000 employees and annual revenues above EUR 450 million.
CBAM (Carbon Border Adjustment Mechanism) – 90% of importers (mainly SMEs and individuals) have been exempted from the CBAM obligation.
Audit of the report– The requirement for “limited assurance” will remain in force. ESG reports will be subject to limited verification by auditors (less rigorous control, based on the analysis of available information and the assessment of the probability of errors).
CSDDD requirements – Risk assessment in the activity chain will focus on direct business partners (Tier 1) with at least 500 employees hired.
Conclusion
The proposed changes to ESG reporting as part of the Omnibus Package are an important step towards simplifying regulations and reducing the administrative burden on enterprises. For many companies, this means reduced costs and greater flexibility in terms of sustainability activities.
However, the limitation of ESG reporting also comes with serious risks. It may lead to a decrease in transparency on the markets, limit the access of smaller companies to financing and weaken the effectiveness of the EU’s climate policy. A key challenge for businesses will be to find a balance between the benefits of deregulation and the long-term sustainability goals.
Regardless of future legislative decisions, companies should continue to pursue ESG strategies, even if they are not formally required to report. Sustainable development continues to be an increasingly important element of business strategy, which not only generates cost reduction by increasing the efficiency of processes, attracts investors, but also allows for building long-term value and resilience to market changes.
Managing compliance with Extended Producer Responsibility (EPR) regulations can be particularly challenging for smaller businesses, which often operate with limited budgets and resources. However, there are several strategies these businesses can adopt to minimize costs while fulfilling their obligations.
Join collective compliance schemes
Many small producers can benefit from joining compliance schemes or producer responsibility organizations (PROs). These schemes handle much of the administrative and logistical burden of EPR compliance, including waste collection, recycling coordination, and reporting. While there are membership fees involved, the shared infrastructure and expertise significantly reduce costs compared to setting up independent compliance systems.
EFF can help your business simplify this process further! Instead of having to contact and coordinate with a unique PRO for each of your products and markets, partner with EFF with our EPR Attorneys will be your one-stop shop for organising all of these communications. We’ll work with you and the PROs to understand each of your requirements and make sure that you are meeting all your obligations in a timely manner.
Start simplifying your processes now!
Schedule a meeting with one of our experts and see how we can help your business. Contact us to discuss the details.
Redesigning products and packaging to align with recyclability and sustainability standards can reduce modulated EPR fees. For instance, using mono-material packaging or incorporating higher levels of recycled content can lower financial obligations under many EPR frameworks. Proactive eco-design can also appeal to eco-conscious customers, creating long-term business value beyond compliance.
Leverage government and industry support
Many EU countries provide financial incentives, grants, or technical support to help small and medium-sized enterprises (SMEs) transition to sustainable practices. These programs can offset costs related to material changes or compliance adjustments. Additionally, working with industry bodies or trade associations can provide access to shared resources and advocacy for proportionate EPR policies.
Streamline reporting and data management
EPR regulations often require detailed reporting, which can be resource intensive. Investing in software or consulting services that automate data tracking and reporting can save time and reduce the likelihood of penalties for inaccuracies. Partnering with compliance specialists ensures that reporting is efficient and adheres to regulatory deadlines.
Engage in supply chain collaboration
Smaller businesses can work closely with suppliers to source compliant materials or optimize packaging for sustainability. By collaborating on eco-friendly solutions, they can achieve compliance while sharing costs and innovation efforts across the supply chain.
By combining these approaches, small businesses can not only reduce the financial burden of EPR compliance but also turn it into an opportunity for innovation and competitive advantage. Strategic adaptation to EPR policies positions these businesses to thrive in a marketplace increasingly driven by sustainability.
