Sustainability Requirements if you’re Exporting to the EU

We may have moved on from Brexit but if you’re an exporter to the EU then you need to keep an eye on what happens with their legislation for the knock-on impacts here in the UK.  There are a few areas where there are imminent impacts to be felt this year.

One of the sources for driving impacts in the field of sustainability is the EU Circular Economy Action Plan 2020 (CEAP).  This aims to make sustainable products, services and business models with a focus on the key sectors of electronics, batteries and packaging, plastics and textiles.

It’s worth noting the interesting inclusion here of the “…aim to make sustainable business models”.  ie. this is looking beyond the end products or services but to the actual company governance systems.  In other words the CEAP is driving action from the top, similar to the leadership aspect in ISO standards.

Some of the regulations supported or driven by the CEAP include the Right to Repair Directive 2024, the Ecodesign for Sustainable Products Regulations 2024 and the EU Corporate Sustainability Due Diligence Directive 2024.  This last Directive requires companies (who meet the threshold limits) to identify, prevent, mitigate and account for negative human rights and environmental impacts within their operations, subsidiaries AND their supply chain.   The initial plans for implementation were July this year but these have been put back to July 2029.  Nonetheless, the era when big businesses can outsource unfavourable environmental impacts or ignore the impact of their supply chain, is drawing to a close. 

The EU Carbon Border Adjustment Mechanism (CBAM) came fully into effect on 1^st January this year, impacting cement, iron and steel, aluminium, fertilisers electricity and hydrogen.   EU companies importing more than the single mass-based threshold of 50 tonnes of CBAM goods into the EU will be impacted by the CBAM tax system. 

A specific directive that is impacting in August 2026 is the Packaging and Packaging Waste Directive (PPWR) 2025.  This mandates strict rules for all packaging to be recyclable, reuseable and clearly labelled.  The initial requirements come into effect for EU companies from August this year when they need to ensure any packaging they use meets the standards of PPWR.  UK exporters therefore, will need to comply with PPWR and  EU EPR rules when selling any packaged goods to the EU.  They will need to provide technical documentation to evidence their recycling content and recyclability of the packaging used, including a Declaration of Conformity,  alongside ensuring packaging is labelled to the standards of the PPWR. 

So the UK may no longer be a member of the EU BUT from the business perspective there are links which have deep implications.  If you export to the EU make sure you keep up to date on their Directives as there is increasing pressure on EU companies to consider and evidence their supply chains when it comes to sustainability.  And from a good practice perspective, think about how you can evidence your sustainability claims – not just ‘knowing’ you use ‘good’ products, but how can you evidence it?

If you want to know more about anything in here then contact Deb@e4environment.co.uk for a chat.