Where are the ESPR, DPP and other EU regulations headed after the Omnibus?
Ecodesign for Sustainable Products Regulation (ESPR)
The Ecodesign for Sustainable Products Regulation (ESPR) is the cornerstone of the Green Deal regulation. It will gradually cover almost all physical products on the EU market, setting mandatory requirements for durability, reparability, recycled content and resource efficiency. The Omnibus did reduce the scope as well as postpone deadlines for key reporting frameworks like ESRS and CSDDD, which means less granular data on material flows, waste, and product impacts for the circular economy. However, in the best-case scenario, simplification reduces fragmentation and transaction costs for circular solutions.
Many might have started wondering if the landscape would start looking very different, and what regulation would finally survive. The good news is that the swerving Omnibus did not run over the ESPR regulation. From 2026 through 2030, the ESPR will begin to apply to selected intermediate and final product groups. On top of this most of the manufacturing companies should make sure to be ready for the ESPR’s horizontal requirements: repairability from 2027, and recycled‑content and recyclability requirements from 2030. More about the legislation can be found from our ESPR fact sheet.
Digital Product Passport (DPP)
ESPR regulation also introduces the Digital Product Passport (DPP), a standardised EU-wide digital ID for products. Companies must provide and upload data on materials, environmental performance, and compliance. Customs and market surveillance will use this for enforcement. ESPR extends ecodesign rules from the previous, narrow set of energy-related products to nearly all goods, including components and intermediates. Learn more about DPP in our article published together with Bluugo.
Still going strong: Packaging and Packaging Waste Regulation (PPWR) and Circular Economy Act (CEA)
Companies should also closely monitor Packaging and Packaging Waste Regulation (PPWR). A phased timeline from 2026 through 2035 will bring concrete obligations to a wide range of packaging industry actors. It tightens rules on recyclability, reuse, and recycled content thus impacting sectors with heavy packaging footprints. It also tightens sector/value chain regulations under CEAP (Circular Economy Action Plan e.g., batteries, textiles and construction products). The forthcoming Circular Economy Act (CEA) is expected to knit these instruments together, strengthen Extended Producer Responsibility (EPR) in some streams, and create a more harmonised single market for secondary raw materials and circular business models, a goal that will be instrumental to decrease Europe’s dependency on raw material imports.
Green Claims Directive was one of the Omnibus Casualties
The Omnibus hit the Green Claims Directive hard. In June 2025, the Commission announced plans to withdraw the draft, citing complexity and cost of third-party verification. However, anti-greenwashing efforts aren’t dead. Parts of the agenda continue via the Empowering Consumers for the Green Transition Directive and updated, detailed guidance on the Commission’s Environment Department’s site. Expect substance to survive, even if the original directive is reshaped or absorbed.
Bottom Line
The broader goal remains the same after Omnibus. In practice, the focal points are slightly different: burden on reporting has been reduced, but at the same time more emphasis is put on improved circularity of materials to reduce European Union’s raw material dependencies and to create the Union’s secondary raw material single market. Improved circularity will bring economic benefits often from the get-go, as it equates improved business design. Setting up capabilities will take time and effort, so the best time to start is still right now.
Stay ahead of these developments. Leveraging ESPR, PPWR, and upcoming frameworks can unlock new opportunities for sustainability and circularity, driving both environmental and economic benefits. Check our article on how circular practices translate to improved financial KPIs.
