EU Sustainability Law: Trends and Expectations for 2025

As we step into 2025, the EU’s sustainability agenda remains firmly in the spotlight. The coming year promises both challenges and opportunities for businesses navigating the intricate web of regulations designed to foster a greener, more competitive Europe.

But what exactly should European businesses be preparing for? If you are keen to know what’s coming next, keep reading and enjoy our team’s expert analysis of the key legislative developments you can expect in 2025, plus an overview of the trends that will govern what happens in Brussels in the near future.

Want someone with deep experience and connections in the EU to help guide your sustainability strategy? Get in touch!

2025: A Year of Transition and Action

2025 marks the first year of the new mandate for the European Commission, referred to as the von der Leyen Commission II. This transition sets the stage for significant activity in the first quarter, as the Commission begins to implement its 2024-2029 agenda. For organisations engaged in EU policymaking, this is a pivotal year to influence the direction of new initiatives announced in late 2024.

Key aspects of the new mandate include:

• The continuation of the EU Green Deal, albeit with a stronger focus on competitiveness and simplification.
• Implementation of political guidelines and mission letters published in Q4 2024.
• Clarification of the Draghi report recommendations, particularly around reducing red tape and enhancing efficiency.

Trends For EU Sustainability Legislation in 2025 and Beyond

The EU’s sustainability agenda will continue to evolve, with many key policies being refined and finalised, reflecting both the urgency of environmental challenges and the need for a more competitive and resilient economy. Decarbonisation and digitalisation should serve as essential tools for boosting EU competitiveness, accompanied by a stronger emphasis on policy enforcement, process simplification, and reducing administrative burdens.

One of the important trends we can expect to see in 2025 and the coming years will be a push to secure the bloc’s independence. This should include efforts aimed at cutting import dependencies while fostering investments through public-private cooperation, particularly in research and innovation. Fair-trade agreements and the facilitation of direct investments will also be prioritised, with special attention given to providing adequate support to SMEs, ensuring that businesses of all sizes contribute to and benefit from the EU’s sustainability ambitions.

The Green Deal will remain a priority but with a focus on its implementation, under the competitiveness pillar. In this environment, robust public affairs strategies will be more important than ever. Advocacy will play a critical role not only in keeping the Green Deal moving forward, but also in ensuring that our push for competitiveness does not come at the expense of key aspects of the environmental agenda, such as biodiversity support and preservation, for example.

2025: Our Forecast for Key EU Sustainability Files

The first quarter of 2025 will be marked by a series of important publications that will shape the EU’s legislative priorities for the coming years:

• 15 January: Competitiveness Compass.
• 5 February: Communication on e-commerce platform challenges.
• 11 February: 2025 Commission Work Programme.
• 19 February: Vision for Agriculture and Food.
• 26 February: Clean Industrial Deal and Omnibus Simplification Package.
• 5 March: Union of Skills and Roadmap for Women’s Rights.

Additionally, major initiatives from von der Leyen’s first mandate will continue to unfold. These include:

• Finalising the Waste Framework Directive and Green Claims legislation, along with associated secondary consultations.
• Publication of the legislative proposal on textile labelling revisions in Q2.
• Delegated acts under the Ecodesign for Sustainable Products Regulation (ESPR), covering apparel, textiles, and more.
• Ongoing consultations on the Corporate Sustainability Due Diligence Directive (CSDDD).
• Revision of the bioeconomy strategy – with bio-based textiles expected to be in scope.
• Revision of the Circular Economy Act.
• Revision of REACH – PFAS restrictions.

While the Green Deal remains a key framework, 2025 signals a shift in priorities towards competitiveness and simplification. Businesses must bring forward their ESG learnings from the past four years to ensure the Green Deal continues driving positive impacts while becoming more manageable for businesses. Expect the Commission to utilise omnibus legislative vehicles to streamline overlapping legislation and reduce regulatory burdens, offering opportunities to address formal and potentially essential aspects of existing laws.

Ecodesign for Sustainable Products Regulation

“The ecodesign requirements for apparel textiles will introduce more sustainable products to the EU market, and in the coming years, consumers will not only notice these changes but also gain a deeper understanding of the EU’s commitment to fostering sustainability and advancing a circular economy for the benefit of future generations.” – Analoli del Cueto Menéndez, Junior Consultant – Circularity

The Ecodesign for Sustainable Products Regulation (ESPR) is a cornerstone to the EU’s green transition and will transform how products are designed and commercialised in the Single Market. In 2025, we expect that establishing detailed product-specific requirements will be a priority for the European Commission, covering aspects such as durability, repairability, and recyclability. We are keen to see the results of the preparatory work on ESPR for apparel, which will provide much-needed clarity on the rules brands and manufacturers must comply with in the coming years. Although these rules will require a significant operational shift from the textile industry, they should work to improve business practices, boost innovation and place more sustainable products on the market.

“Businesses that adopt proactive measures to align their product development with these requirements will gain a competitive advantage, both in regulatory compliance and consumer appeal. Companies should also watch for updates on the Digital Product Passport, which will tie closely to ESPR objectives.” – Rannveig van Iterson, Head of Circularity

EU Digital Product Passport

The Digital Product Passport (DPP) will be a digital information tool introduced by the ESPR, to provide comprehensive information regarding the environmental and sustainability aspects of products sold in the EU. We expect the Commission to place more focus on the DPP this year, with product-specific requirements outlined in the delegated acts under the ESPR. Progress on harmonised standards will continue, addressing technical specifications and interoperability, although the final requirements likely won’t be ready before the end of the year.

“While the DPP for textiles will become mandatory only in 2028, businesses should already start looking into possible digital infrastructure upgrades, and prepare to align their processes and systems with upcoming requirements.” – Jędrzej Nadolny, Consultant – Transparency & Supply Chain

Waste Framework Directive

The Waste Framework Directive (WFD) will play a critical role in shaping Europe’s waste management landscape, and the amends to the WFD are expected to place a stronger emphasis on the prevention and management of waste streams, particularly in high-impact sectors like food and textiles. This year we will have the highly anticipated outcomes of the WFD’s trilogues, and we are particularly curious to see whether extrinsic durability will be included in the final law. If adopted, this concept could have a significant impact on the fashion industry. We remain hopeful that the trilogues will address existing uncertainties and lead to a harmonised framework that aligns with the highest standards.

“We also strongly support a swift transposition and implementation of Extended Producer Responsibility schemes by Member States. Despite the challenges in implementation, these measures are vital for advancing the circular economy, especially in scaling textile-to-textile recycling.” – Rannveig van Iterson, Head of Circularity

EU Green Claims Directive

The Green Claims Directive (GCD) will advance the EU’s efforts against greenwashing, and this year we should find out more about how that will happen in practice. In 2025, we expect to have clearer and more enforceable standards for environmental claims, with additional details provided on acceptable verification methods and substantiation requirements. The trilogues on the GCD are expected to finish around mid-2025, followed by Member State implementation. The law should start applying in the second half of 2028.

“More than worrying about reviewing their current marketing and product claims to ensure full compliance, companies should see this as an opportunity to differentiate themselves, building trust among the ever growing base of environmentally conscious consumers.” – Jędrzej Nadolny, Consultant – Transparency & Supply Chain

EU Textile Labelling Regulation

2025 will bring about the revision of the EU Textile Labelling Regulation (TLR), with the goal of harmonising labelling practices while also promoting sustainability within the textile sector. The Commission is expected to publish the TLR revision proposal in Q2 of this year, introducing new guidelines for physical and digital textile labels, including specifications related to sustainability and circularity, in alignment with the ESPR. While the start of application is still unknown, it should likely be around between 2027 and 2028.

“The TLR revision could be highly impactful for the fashion industry as a whole, since a potential expansion of the regulation to encompass all types of apparel, rather than focusing solely on textile-based products, is currently being considered.” – Jędrzej Nadolny, Consultant – Transparency & Supply Chain

Staying Ahead

For organisations active in Brussels, 2025 is not a year to slow down. It’s a year to stay engaged with ongoing files while proactively shaping new initiatives. As the focus shifts towards simplification and competitiveness, businesses have an opportunity to influence how sustainability goals are balanced with economic realities. The agenda ahead is both ambitious and transformative, demanding strategic foresight and active participation.

Adapting to a New Mandate

As the EU transitions into a new mandate, organisations active in Brussels need to look beyond the current advocacy pipeline and adapt their strategies. This involves focusing on three critical activities:

1. Compliance: Work on the implementation and transposition of EU legislation into national frameworks. Organisations should identify and address any challenges, flagging issues to the European Commission and local governments. The simplification and competitiveness agenda, including the omnibus simplification package, presents significant opportunities in this area.
2. Ongoing Engagement: Continue active involvement in key files still under development, such as the Ecodesign for Sustainable Products Regulation (ESPR).
3. Forward Thinking: Think creatively about desired outcomes for upcoming initiatives, including the Circular Economy Act, biodiversity policies, and other forward-looking legislation.

By aligning with these priorities, businesses can position themselves as proactive contributors to the EU’s evolving agenda.

Ohana’s Takeaways

2025 is poised to be yet another transformative year for EU sustainability legislation, with significant implications for organisations across all sectors. With the deadlines for the bloc’s many environmental goals quickly approaching, developing and implementing a well thought out sustainability strategy has become an urgent necessity for EU businesses, especially those in high-impact industries such as agri-food, fashion and textiles.

At Ohana, we are specialists in doing just that: guiding the most forward-thinking European companies through this evolving landscape, helping them identify and seize all the emerging opportunities.

If you’re looking to ensure compliance while maximising your competitive edge in the new year and beyond, our experts are ready to help. Get in touch and learn more about how our tailored services can support your sustainability journey!

Want someone with deep experience and connections in the EU to help guide your sustainability strategy? Get in touch!

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