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In order to implement the so-called “Green Deal,” the EU has, in recent years, adopted ambitious sustainability rules. The aim of the Green Deal is to make the EU climate-neutral by 2050. As a first step, emissions within the EU are to be reduced by at least 55% by 2030. The regulatory frameworks adopted for this purpose, namely the Carbon Border Adjustment Mechanism (CBAM), the Regulation on deforestation-free supply chains (EUDR), and the so-called Supply Chain Directive (CSDDD), impose a considerable administrative burden on the companies affected and place particular strain on small and medium-sized enterprises. These instruments have accordingly drawn a great deal of criticism, prompting the EU Commission to put forward proposals aimed at reducing the administrative burden on companies (see the press release of 26 February 2025 on this<\/a><\/strong>). The proposals contain the following adjustments:<\/p>\n\n\n\n 1. Sustainability reporting (CSRD)<\/strong><\/p>\n\n\n\n 2. The “EU Supply Chain Directive” (CSDDD)<\/strong> The volume of information large companies can request from SMEs and small businesses is to be reduced. The major point of contention around civil liability, which, unlike under the German LkSG, had found its way into the Directive, is now, after all, to be removed. 3. Carbon Border Adjustment Mechanism (CBAM)<\/strong> The Commission’s current proposals to amend the relevant directives and regulations fall under the term “Omnibus Initiative” and are available for download under the headings Omnibus 1 <\/a><\/strong>and Omnibus 2<\/a><\/strong>. The proposals are now being deliberated in the legislative process. According to the press release<\/a><\/strong>, the EU Commission intends to press the European Parliament and the Council to give this legislative package priority treatment.<\/p>\n\n\n\n We will keep monitoring further developments for you!<\/p>\n\n\n\n\n
Rather than being required to look at the entire value chain, companies will, similarly to the German LkSG, be able to focus on their direct business partners. Risk assessments will move from an annual cycle to a five-year cycle.<\/p>\n\n\n\n
oOverall, companies are to be given more time to prepare for the new requirements, with the Directive’s application date pushed back by one year, to 26 July 2028.<\/p>\n\n\n\n
Small importers, in particular SMEs and private individuals, will be exempted from CBAM obligations. Simplifications are planned for companies that continue to fall within CBAM’s scope. In the longer term, the rules for preventing circumvention are to be made more effective. A new legislative proposal on the scope of CBAM is being prepared and is expected to be presented in early 2026.<\/p>\n\n\n\n