Basecamp is Live!
Explore EU sustainability insights in one place. Sign up today
Explore EU sustainability insights in one place. Sign up today
Welcome to The Ohana Brief. Ohana is the boutique consultancy making EU sustainability policy simple, actionable and (dare we say) a little less overwhelming for the businesses navigating it. This is our monthly EU Sustainability Edit: the policy shifts, deadlines and debates you should have on your radar.
There is a strong “back to school” feeling among the Ohana team this month. Not only because autumn in Brussels is packed with events, but also because there’s lots of movement on the policy side. That’s what makes this the perfect moment to launch the new Ohana newsletter, which I’m really excited to share with you.
The aim for this newsletter is to complement our well-established blog and bring updates from the Brussels policy world on issues as wide ranging as the circular economy, sustainability in textiles and agri-food, but also start to delve into some emerging sectors for Ohana: furniture and footwear.
But this is not just another news update! With this newsletter we aim to help you make sense of complex EU policy moments: what they mean for business, how they will work in practice and whether there is scope to act or engage. We also want to use this newsletter to help build and galvanise a community of like-minded people and organisations, who are thinking seriously about how policy can deliver real world impact.
At Ohana we share the belief that through deep expertise and rigorous thinking, alongside the courage and the drive to act on it, we can create change – together!
We’d love to share more about other new developments at Ohana, including giving you a “sneak peak” of Basecamp – our online guide through EU policy – at a drinks reception on Wednesday 4th November. Register here.
I hope you enjoy this first edition. Let us know what you think!
Pascale Moreau
Founder of Ohana
Since this is the first edition, please indulge a little retrospective… When I started Ohana in 2019 we were in a different era: this was right at the beginning of the EU Green Deal and the mood was poles apart. Sustainability was seen as Europe’s growth strategy. The language was around climate neutrality, transformation and raising ambition. Both the vocabulary and the focus have shifted; now the buzz words are competitiveness, simplification, resilience, industrial capacity and reducing regulatory burden.
Last week’s State of the Union address was a pretty clear illustration of that shift. EU Commission President, Ursula von der Leyen avoided direct mention of climate action, instead framing the focus largely around resilience, preparedness, clean energy and energy independence, alongside a much broader focus on strengthening Europe’s economy, cutting administrative burdens and reinforcing its industrial base.
But has the problem changed? No, if this summer has shown us anything in Europe, it should have hammered home that climate change is indeed a crisis. And whilst the vibe in the EU institutions and in some EU capitals has changed and the emphasis may have moved on, it does not make climate change, resource-use or the need to decarbonise European industry any less real.
And business, indeed the ones that we work with, are already on board with that transformation. So this is not a simple equation: business = pro-deregulation. They are already making the changes within their businesses to reduce the impact on the world around them. But what they need to know is what simplification means, what are its practical implications.
Competitiveness + sustainability = perfect bedfellows?
After around 18 months of omnibus and “simplification” debates in Brussels, there’s a risk of “simplification-fatigue”, even among those businesses that were initially on board with meeting stronger sustainability requirements.
Companies need regulatory stability. Those that moved early to implement sustainability requirements should be rewarded for their efforts. But constant updates to EU requirements, risk rewarding those that lag behind rather than those that moved first.
A recent DG GROW paper on responsible business conduct (RBC) looks at competitiveness, resilience and decarbonisation as a “trilemma”, but also shows how responsible business practices can support long-term competitiveness through stronger governance, supply-chain risk management and resilience. The paper shows that RBC can support long-term competitiveness through innovation, productivity and better risk management. Yes, sustainability does not come without investment, and clear, predictable and well-designed policy can help make the business case for that investment.
And, anecdotally, we can see how policy uncertainty is playing out. Businesses are cutting back on sustainability hiring and headcount in general has been affected. Meanwhile internal budgets are being reorganised and wider investment decisions either put on hold or shifting elsewhere (away from sustainability). How, therefore, can policy square the circle, identified by the DG Grow report, whilst (many) businesses are cutting back in this area?
And so a wider strategic question emerges: how can the EU simplify where necessary without weakening incentives for companies that have already invested in sustainability? The EU should be supporting those industries and companies who have already implemented the more stringent legislation, rather than those that were slow on the uptake! This is a big debate and goes beyond the sectors we work closely with, but it’s something we’ll be keeping an eye on and no doubt will return to this in future editions.
Commission explores VAT reform to support the circular economy
The Commission has launched a consultation – open until 4 November – on a potential Circular VAT initiative. The initiative seeks to better align the existing EU VAT Directive with circular economy principles and circular business models, including in the areas of treatment of second-hand goods and destruction of viable goods. Commission adoption is planned for Q1 2027. This initiative will likely feed into the Circular Economy Act (CEA), whose publication, originally expected by the end of September, is now slated for publication towards the end of the year.
This is a clear signal from the Commission that it is looking beyond specific product regulations to the conditions which underpin circular business models. VAT is clearly going up the agenda in the policy debate, particularly where current tax treatment creates disincentives for re-use, repair or second-hand markets.
Commission sets out how the Forced Labour Regulation will work in practice
The Commission has published its implementation guidelines for the Forced Labor Regulation (FLR). The guidance clarifies the Regulation’s scope, compliance requirements, and investigation and enforcement procedures, reporting through the EU Single Portal, which is now live. The portal provides a central hub for businesses, public authorities and civil society to prepare for the FLR’s application on 14 December 2027, by offering practical guidelines on how the rules work, dedicated support tools for SMEs, a provisional list of competent authorities and initial information on forced labour risk.
With the FLR moving to implementation, companies need to get down to the task of understanding where forced labour risks may exist in their supply chains and they need to make sure that their existing due diligence systems are up to the task if their products come under scrutiny.
DPP rollout advances with new registry and implementation hub
The Commission has launched a dedicated Digital Product Passport (DPP) webpage, providing key information on the DPP framework, implementation timeline, technical standards and DPP registry, which is now also operational. The DPP registry will serve as a database storing unique product identifiers and metadata for each product covered by a DPP. The webpage also outlines the planned rollout of product-specific DPP requirements, including for textiles, expected in Q3–Q4 2027. The DPP will provide a digital record of product-related information, enabling businesses, consumers, repairers, recyclers and public authorities to access reliable information in a more transparent and standardised way.
Are you ready for DPP implementation? Companies in sectors likely to face early DPP requirements now need to turn their attention to data readiness. This may include better understanding what product information they hold, where it sits across the value chain and whether it can be exchanged in the required format. Read our recent blog for more on this.
When you think of furniture, you often think of the final product and the consumer’s experience of that, what is less apparent is what’s under the surface (or the upholstery!).
A whole raft of EU regulations apply to a sofa’s component parts and EU policy is set to become even broader in this area. New requirements relating to sustainability, circularity, how products are designed and which information is available across the value chain are set to change what companies need to know (and make public) about the materials they use in their products.
As part of our growing work with the furniture sector, we wanted to take a practical look at what this evolving policy landscape means. So for our latest blog, we have (figuratively) dismantled a sofa to see which EU regulations apply to which parts of a sofa. From that we can extrapolate what this shift means for the furniture sector in practice and how businesses should be responding. It’s actually the perfect moment for operators in the furniture sector to engage in EU policy; not only to understand what that upcoming regulations will mean for them, but also to help shape future policy which affects their business, so that it is both ambitious and also delivers, whilst remaining pragmatic for the sector to implement. With our strong track record in adjacent sectors such as home textiles and circularity, Ohana’s work in this area marks a natural evolution into a sector that has loads of potential for increased circularity and reducing its impact.
Read the full blog and find out more about Ohana’s work for the furniture sector.
If you’re planning on coming along to any of these, then drop us a line beforehand and let’s grab a coffee.
We hope this newsletter becomes a useful place for you to regularly catch up on EU policy both at a high level, covering the bigger shifts, as well as the detail, highlighting where those changes start to affect sectors, organisations and day-to-day decisions. We’ll also be bringing, in future editions, interviews with thought leaders from our sector and more deep dives and explainers. Stay tuned!
If you found it useful, do forward it to colleagues or contacts who might be interested. And we’re always happy to hear your feedback!